QASSIM et al v. BUSH et al

Filing 23

QASSIM et al v. BUSH et al

Doc. 23

UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA ABU BAKKER QASSIM and A'DEL ABDU AL-HAKIM, Detainees, Guantánamo Bay Naval Station, Guantánamo Bay, Cuba; Petitioners/Plaintiffs, v. GEORGE W. BUSH, et al., Respondents/Defendants. NOTICE OF FILING TO THE COURT AND COUNSEL FOR RESPONDENTS: PLEASE TAKE NOTICE THAT, in compliance with Judge Green's November 8, 2004 Amended Protective Order and December 10, 2004 Order Supplementing and Amending Filing Procedures Contained in November 8, 2004 Amended Protective Order, Petitioners submitted the following documents to the Court's designated Court Security Officer on July 20, 2005: · · · · Petitioners' Emergency Motion to Vacate Stay Order and Issue Writ Directing Immediate Release of Petitioners; Memorandum in Support of Petitioners' Emergency Motion to Vacate Stay Order and Issue Writ Directing Immediate Release of Petitioners; Declaration of Sabin Willett; and [Proposed] Order Granting Petitioners' Emergency Motion to Vacate Stay Order and Issue Writ Directing Immediate Release of Petitioners. Case No. 05-0497 (JR)

Petitioners' Emergency Motion is based on newly discovered, dispositive information. Based on this critical information, which Respondents have withheld from the Court and from counsel, Petitioners respectfully request that the Court vacate the previous stay of this action,

DCDOCS/630468.2

Dockets.Justia.com

order that Petitioners be immediately released from their imprisonment, and that the Court hold a prompt hearing to address the practical issues raised by Petitioners' release.

Dated: July 22, 2005

/s/ Sabin Willett Neil McGaraghan Jason S. Pinney Daniel Hunter Kiel BINGHAM McCUTCHEN LLP 150 Federal Street Boston, MA 02110-1726 Telephone: [phone] Facsimile: [phone]

Susan Baker Manning BINGHAM McCUTCHEN LLP 1120 20th Street, NW, Suite 800 Washington, DC 20036 Telephone: [phone] Facsimile: [phone]

Barbara Olshansky Deputy Director CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012 Telephone: [phone]

-2DCDOCS/630468.2