IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 1082

MOTION for Joinder in Opposition to Government's Motion for Reconsideration by JAMIL AHMAD SAEED (Rashkind, Noah)

IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Doc. 1082

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA __________________________________________ ) IN RE: ) ) GUANTANAMO BAY ) DETAINEE LITIGATION ) ) __________________________________________) ) JAMIL AHMAD SAEED, ) also known as JAMIL AHMED SAID NASSIR ) Detainee ISN #728, etc. ) ) Petitioner, ) v. ) ) GEORGE W. BUSH, etc., et al., ) ) Respondents. ) __________________________________________)

Misc. No. 08-442 (TFH)

Civil Action No. 05-2386 (RBW)

PETITIONER JAMIL AMHAD SAEED'S JOINDER IN OPPOSITION TO THE GOVERNMENT'S MOTION FOR RECONSIDERATION Petitioner Jamil Ahmad Saeed, a/k/a Jamil Ahmed Said Nassir, Detainee ISN #728, through undersigned counsel, hereby joins in the "Opposition to the Government's Motion for Reconsideration and Cross-Motion to Strike Hayden Declaration and to Transfer this Case Back to the Merits Judge for all Further Proceedings," filed today by petitioner in Civil Action No. 05-392 (ESH) (D.E. #121); Civil Miscellaneous Case No. 08-442 (TFH) (D.E. #1067), and in the "Memorandum in Opposition to Motion for Clarification and Reconsideration of the Court's Case Management Order and in Support of Cross-Motion to Strike," filed today by petitioners in Civil Action No. 02-0828 (CKK) (D.E. #406); Civil Miscellaneous Case No. 08-442 (TFH) (D.E. #1059). In addition, Petitioner Saeed advises the Court that the government has failed to furnish a factual return for Petitioner Saeed, even though it has done so for other petitioners whose petitions were

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filed later in time. Together, the government's failure to file a factual return, in conjunction with the present motion for reconsideration as to Petitioner Saeed is an unreasonable delay of the proceedings to which he is entitled under Boumediene v. Bush, 128 S. Ct. 2229 (2008).

Respectfully submitted, /s/ Noah H. Rashkind Noah H. Rashkind, Esq. Counsel for Petitioner Saeed 2411 SW 35th Place, #206 Gainesville, Florida 32608 Tel: [phone] Email: [e-mail]

CERTIFICATE OF SERVICE I hereby certify that on November 26, 2008, I filed the foregoing electronically through the CM/ ECF system, which caused the following counsel to be served by electronic means, as more fully reflected on the Notice of Electronic Filing: Terry Marcus Henry [e-mail] Andrew I. Warden [e-mail] Judry Laeb Subar [e-mail] James C. Luh [e-mail]

/s/ Noah H. Rashkind Noah H. Rashkind, Esq.