IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 1586

RESPONSE TO ORDER OF THE COURT re (135 in 1:06-cv-01690-RBW) Order,,, filed by MAJID KHAN, RABIA KHAN, GUANTANAMO BAY DETAINEE LITIGATION. (Dixon, J.)

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IN RE: GUANTANAMO BAY DETAINEE LITIGATION Doc. 1586 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­ x : IN RE: : : GUANTÁNAMO BAY : Misc. No. 08-442 (TFH) DETAINEE LITIGATION : : ­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­ x : MAJID KHAN, : : Petitioner, : : v. : Civil Action No. 06-1690 (RBW) : GEORGE W. BUSH, et al., : : Respondents. : : ­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­ x RESPONSE TO ORDER OF THE COURT Petitioner Majid Khan, by and through his undersigned counsel, respectfully submits this response to the Court's February 5, 2009 Order (dkt. no. 135). 1. Khan objects to further delay of this case for the reasons set forth in his motion for reconsideration of Judge Hogan's Minute Order, dated February 2, 2009, granting the government an extension of time, until February 27, 2009, to file a factual return (dkt. no. 134). 2. The Court should schedule an initial status conference, promptly upon the government filing a factual return, to address matters concerning (a) application of the government's "enemy combatant" definition to Khan, (b) Khan's entitlement to full constitutional rights based on his legal status in the United States and his other substantial, voluntary ties to this country, and (c) the implications of his undisputed torture. Dockets.Justia.com Dated: New York, New York February 8, 2009 Respectfully submitted, /s/ J. Wells Dixon J. Wells Dixon (Pursuant to LCvR 83.2(g)) Gitanjali S. Gutierrez (Pursuant to LCvR 83.2(g)) Shayana D. Kadidal CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, New York 10012 Tel: (212) 614-6423 Fax: (212) 614-6499 wdixon@ccrjustice.org ggutierrez@ccrjustice.org skadidal@ccrjustice.org Counsel for Majid Khan -2-

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