Filing 1399

MOTION Request for Expedited Briefing and Ruling/Hearing on Motion for Direct Contact with Client re (1378 in 1:08-mc-00442-TFH, 52 in 1:08-cv-01235-JDB) MOTION for Order by GUANTANAMO BAY DETAINEE LITIGATION, AHMED YASLAM SAID KUMAN (Attachments: # 1 Text of Proposed Order)(Gunn, Carlton)

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IN RE: GUANTANAMO BAY DETAINEE LITIGATION Doc. 1399 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA _________________________________ ) IN RE: ) ) GUANTANAMO BAY DETAINEE ) LITIGATION ) _________________________________) ) AHMED ISLAM SAID KUMAN ) ) Petitioner, ) ) v. ) ) GEORGE W. BUSH, et al., ) ) Respondents. ) _________________________________) Misc. No. 08-442 (TFH) Civil Action No. 08-CV-1235 (JDB) REQUEST FOR EXPEDITED BRIEFING AND RULING/HEARING ON MOTION FOR DIRECT CONTACT WITH CLIENT On December 22, 2008, Petitioner filed a Motion for Direct Contact with Client, in which he seeks a court order that, if guard personnel claim that Petitioner refuses to meet with counsel on their next visit to Guantanamo Bay, there be two forms of potential relief provided: (1) that counsel's Arabic speaking interpreter be allowed to go back to speak to Petitioner directly and explain to him why it is in his interest to meet with counsel; and (2) if this does not work, defense counsel be allowed to meet privately with Mr. Al Wady in the camp in which he is actually detained, so that defense counsel may personally explain their role and their purpose. It is noted in the motion that counsel plan their next trip to Guantanamo Bay on January 19, 2009. Because trips to Guantanamo Bay and interpreter assistance on such trips generally must be scheduled at least a month in advance, it is important that there be a court ruling on the Motion for Direct Contact with Client before counsel's January 19 trip. Petitioner therefore requests that the Court set a schedule for briefing and ruling on the motion that is somewhat more expedited than normal. Petitioner proposes that the government be directed to file a response to the motion no later than January 5, 2009, that Petitioner file any reply no later than January 9, 2009, and that the Court hold a hearing and/or issue a ruling no later than January 13, 2009. A proposed order is being lodged with this request. Petitioner leaves it in the Court's discretion whether the motion should be heard and ruled on by United States District Judge Hogan or the merits judge. DATED: December 23 , 2008 Respectfully submitted, ____/S/__________________________________ CARLTON F. GUNN (CA Bar No. 112344) CRAIG HARBAUGH (D.C. Bar No. 974117) Deputy Federal Public Defenders Office of the Federal Public Defender 321 East 2nd Street Los Angeles, CA 90012 (213) 894-1700; Facsimile: (213) 894-0081 Attorneys for Petitioner P:\Gunn\GUANTANAMO Kuman\_DirectContactMotionSchedulingRequest.wpd 2

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