IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 1545

NOTICE of Filing of Praecipe and Memorandum of Understanding and Acknowledgment of Jessica Baen (Paralegal) by DJAMEL AMEZIANE, MUHAMMED KHAN TUMANI, ABD AL NISR KHAN TUMANI, ABU ABDUL RAUF ZALITA, OMAR DEGHAYES, MOHAMMED AL-QAHTANI, MANEA AHMED FAHAD AL-QAHTANI, MOHAMMED AL PALESTINI, ABDUL AZIZ NAJI, ABU RAWDA, ABDUL RAZAK ALI, MOHAMMED ABDULLAH TAHA MATTAN, MAHER EL FALESTENY, SHARGOWI LNU, JABBAROV OYBECK JAMOLOVICH, SANAD ALI ALKALIEMI, ABDURAHMAN LNU, ALI LNU, EDRESS LNU, MOHAMMED AHMED SAEED HIDAR, SAIF ULLAH, SAMIR LNU, SHARAF AL SANANI, NADIR OMAR ADULLAH BIN SAADOUN ALSAARY, ABD AL ZAHER, ABDULLAH BO OMER HAMZA YOYEJ, ABDULAZIZ LNU, SAYF BIN ABDALLAH, JAMIL AHMAD SAEED, ALKHADR ABDULLAH AL YAFIE, TOFIQ NASSER AWAD AL BIHANI, MOHAMMED AHMED SLAM AL-KHATEEB, BILAL LNU, ADEL LNU, ABDUL-RAHMAN ABDO ABULGHAITH SULAIMAN, MOHAMMED KAMEEN, SABRY MOHAMMED, SALEH, MUHAMMED SAAD IQBAL MADNI, RIAD NARGERI, ALI ABDULLAH ALI, MOHAMMED AHMED TAHER, MOHAMMED SULAYMON BARRE (Kadidal, Shayana)

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IN RE: GUANTANAMO BAY DETAINEE LITIGATION Doc. 1545 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA IN RE: GUANTANAMO BAY DETAINEE LITIGATION Misc. No. 08-0442 (TFH) Civil Action Nos. 05-0392, 05-0526, 051220, 05-1971, 05-2385, 05-2386, 06-cv1684, 08-1153 PRAECIPE Undersigned counsel for Petitioner respectfully states as follows: 1. According to the terms of the Protective Order entered by this Court in the above-captioned cases on September 11, 2008, "Petitioners' counsel to be provided access to classified information shall execute the MOU appended to this Protective Order, and shall file executed originals with the Court and submit copies to the CSO and government counsel. Such execution, filing, and submission of the MOU is a condition precedent to a petitioners' counsel having access to, or continued access to, classified information for the purposes of these proceedings." Protective Order and Procedures for Counsel Access to Detainees at the United States Naval Base in Guantanamo Bay, Cuba, ¶ 17. 2. The Protective Order further provides, "Without authorization from the government or the Court, protected information shall not be disclosed or distributed to any person or entity other than ... petitioners' counsel, provided such individuals signed the Acknowledgment, attached hereto as Exhibit B, attesting to the fact that they have read this Protective Order and agree to be bound by its terms ...." Id. ¶ 35(a). 3. The Protective Order defines "petitioners' counsel" to include "attorneys employed or retained by or on behalf of a petitioner for purposes of representing the Dockets.Justia.com petitioner in habeas corpus or other litigation in federal court in the United States, as well as co-counsel, interpreters/translators, paralegals, investigators and all other personnel or support staff employed or engaged to assist in the litigation." Id. ¶ 11 (emphasis added). 4. Jessica Baen is a paralegal employed by the Center for Constitutional Rights (CCR). She assists CCR attorneys in their representation of several Guantánamo Bay detainees and has TOP SECRET//SCI security clearance status. In order to accompany CCR attorneys on visits with our clients at Guantánamo, and access classified and protected information concerning our clients, the Protective Order entered in this case requires that Ms. Baen file an executed Memorandum of Understanding Regarding Access to Classified National Security Information and an Acknowledgement regarding the most recent version of the Protective Order entered in this case on September 11, 2008, which are attached here as Exhibit A. Dated: New York, New York January 26, 2009 Respectfully submitted, Counsel for Petitioner: /s/ Shayana Kadidal (D.C. Bar No. 454248) CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, New York 10012 Tel: (212) 614-6438 Fax: (212) 614-6499 2

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