IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 14

Unopposed MOTION for Protective Order by ABDURRAHMAN ABDALLAH ALI MAHMOUD AL SHUBATI (Attachments: # 1 Exhibit 1 11-8-04 Amended Protective Order, # 2 Exhibit 2 11-10-04 Order Addresing Designation Procedures for "Protected Information", # 3 Exhibit 3 12-13-04 Order Supplementing and Amending Filing Procedures Contained in November 8, 2004 Amended Protective Order, # 4 Text of Proposed Order)(Rushforth, Brent) Modified on 7/8/2008 adding filer information(td, ). Modified to correct party filer's name on 7/10/2008 (tg, ).

IN RE: GUANTANAMO BAY DETAINEE LITIGATION

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ABDURRAHMAN ABDALLAH ALI MAHMOUD AL SHUBATI, Petitioner/Plaintiff, v. GEORGE W. BUSH, et al., Respondents/Defendants. PETITIONER'S UNOPPOSED MOTION TO ENTER PROTECTIVE ORDER In this unopposed motion, Petitioner respectfully moves the Court to enter the November 8, 2004 Protective Order, as amended on November 10, 2004 and December 13, 2004, in the In re Guantanamo Bay Detainee Cases, Civil No. 02-0299, et al., by Judge Joyce Hens Green. A copy of the proposed Protective Order is attached hereto as Exhibit 1. The amendments to the Protective Order are attached as Exhibits 2 and 3.1 The Supreme Court's recent decision in Boumediene v. Bush, No. 06-1195, Slip op. at 66 (June 12, 2008) establishes that this court has jurisdiction to consider Petitioner's writ of habeas corpus. Consequently, the United States does not contest that entry of the habeas protective order is appropriate. Entry of the protective order is necessary for Petitioner's counsel to meet the litigation demands of Petitioner's pending In consenting to the entry of the habeas protective order, Respondents reserve their right to seek modifications to the protective order and supplemental orders as appropriate. Respondents' consent to entry of the orders is without prejudice to such a right.
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MISC. NO. 08-442 (TFH) CIVIL ACTION NO. 07-CV-02338 (HHK)

Dockets.Justia.com

habeas action. For these reasons, Petitioner respectfully moves the Court to enter the protective order in this case. Dated: July 7, 2008 Respectfully submitted, Counsel for Petitioner: /s/ Brent N. Rushforth Brent N. Rushforth (DC 331074) Kit A. Pierson (DC 398123) HELLER EHRMAN LLP 1717 Rhode Island Avenue, NW Washington, DC 20036 Tel: [phone] Fax: [phone] Shayana Kadidal (DC 49512) Pardiss Kebriaei (DC 51395) CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, New York 10012 Tel: [phone] Fax: [phone]

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ABDURRAHMAN ABDALLAH ALI MAHMOUD AL SHUBATI, Petitioner/Plaintiff, v. GEORGE W. BUSH, et al., Respondents/Defendants. CERTIFICATE OF SERVICE I hereby certify that, on this 7th day of July, 2008, I caused a true and correct copy of the PETITIONER'S UNOPPOSED MOTION TO ENTER PROTECTIVE ORDER to be served electronically via the ECF system on: TERRY M. HENRY ANDREW WARDEN JUDRY SUBAR United States Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Ave., N.W. Washington, DC 20530 Tel: [phone] Fax: [phone] Counsel for Respondents /s/ Brent N. Rushforth CIVIL ACTION NO. 07-CV-02338 (HHK) MISC. NO. 08-442 (TFH)

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