IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 1010

NOTICE of Filing by Ahmed Ghappour of Documents Required by Protective Order by ISMAIL MOHAMED, ALI MOHAMED (Katznelson, Zachary)

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ISMAIL MOHAMED, et al., ) ) Petitioners/Plaintiffs, ) ) v. ) ) ROBERT GATES, ) ) Respondent/Defendant. ) _____________________________________ ) Misc. No. 08-442 (TFH) Civ. No. 08-1789 (RWR) MEMORANDUM OF UNDERSTANDING REGARDING ACCESS TO CLASSIFIED NATIONAL SECURITY INFORMATION Having familiarized myself with the applicable statutes, regulations, and orders related to, but not limited to, unauthorized disclosure of classified information, espionage and related offenses; The Intelligence Identities Protection Act, 50 U.S.C. 421; 18 U.S.C. 641; 50 U.S.C. 783; 28 C.F.R. 17 et seq.; and Executive Order 12958; I understand that I may be the recipient of information and documents that belong to the United States and concern the present and future security of the United States, and that such documents and information together with the methods and sources of collecting it are classified by the United States government. In consideration for the disclosure of classified information and documents: (1) I agree that I shall never divulge, publish, or reveal either by word, conduct or any other means, such classified documents and information unless specifically authorized in writing to do so by an authorized representative of the United States government, or as expressly authorized by the Protective Order entered in the United States District Court for the District of Columbia in the above captioned cases. (2) I agree that this Memorandum of Understanding and any other non-disclosure agreement signed by me will remain forever binding on me. (3) I have received, read, and understand the Protective Order entered by the United States District Court for the District of Columbia in the above-captioned cases, and I agree to comply with the provisions thereof. Dated: November 19, 2008 Ahmed Ghappour Reprieve P.O. Box No. 52742 London, England EC4P 4WS Telephone: +44 207 353 4640 ahmed@reprieve.org.uk Counsel for Petitioners ACKNOWLEDGMENT The undersigned hereby acknowledges that he/she has read the Protective Order first entered on September 11, 2008, in the United States District Court for the District of Columbia in the consolidated cases captioned In re Guantanamo Bay Detainee Litigation, No.08-mc-0442, understands its terms, and agrees to be bound by each of those terms. Specifically, and without limitation, the undersigned agrees not to use or disclose any protected information or documents made available to him/her other than as provided by the Protective Order. The undersigned acknowledges that his/her duties under the Protective Order shall survive the termination of this case and are permanently binding, and that failure to comply with the terms of the Protective Order may result in the imposition of sanctions by the Court. DATED: November 19, 2008 Ahmed Ghappour

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