QASSIM et al v. BUSH et al

Filing 24

MOTION to Vacate 23 Notice (Other) PREVIOUSLY FILED WITH CSO AND CLEARED FOR PUBLIC FILING by ABU BAKKER QASSIM, A'DEL ABDU AL-HAKIM. (Attachments: # 1 Memorandum in Support of Petitioners' Emergency Motion# 2 Declaration of Sabin Willett# 3 Text of Proposed Order)(Manning, Susan)

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QASSIM et al v. BUSH et al Doc. 24 B. The Court immediatelyissue writs of habeas col~us directing the governmento release Petitioners from prison; t C. The Court reaffirm, pendingfurther hearing and order, that portion of its April 13, 2005order prohibiting the government from transferring or rending Petitioners to another country, as transfer or rendition to certain countries wouldlikely subject Petitioners to torture or death; D. The Court convene a hearing as soon as possible to address any .practical issues arising fromthe release of Petitioners; and E. just and proper. Dated: JulyZ__O, 2005 Respectfully Submitted, Abu Bakker Qassim and A'del Abdu A1-Hakim, By their attorneys, S abiff'Willett Neil G. McGaraghan Jason S. Pinney Daniel Hunter Kiel BINGHAM McCUTCHEN LLP 150 Federal Street Boston, MA02110-1726 Telephone: (617) 951-8000 Facsimile: (617) 951-8925 Susan Baker Manning BINGHAM McCUTCHEN LLP 1120 20th Street NW,Suite 800 Washington, DC 20036 Telephone: (202) 778-6150 Facsimile: (202) 778-6155 Barbara Olshansky Deputy Director CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012 Telephone: (212) 614-6439 The Court grant Petitioners such other and further relief as maybe 2

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