IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 1738

Unopposed MOTION for Leave to File to Supplement the Record by SHAFIIQ (Attachments: # 1 Exhibit A)(Voorhees, Danielle)

IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Doc. 1738

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA SUFYIAN BARHOUMI, et al., ) ) Petitioners/Plaintiffs, ) ) v. ) ) BARACK H. OBAMA, et al., ) ) Respondents/Defendants. ) ____________________________________)

Civil No. 05-CV-1506 (RMC)

UNOPPOSED MOTION FOR LEAVE TO SUPPLEMENT THE RECORD Petitioner Sufyian Barhoumi respectfully requests that the Court permit him to supplement the record with the declaration of Dr. Sheila Carapico (and attachments) (Exhibit A). In support of this motion, Petitioner states as follows: 1. Counsel for Petitioner has conferred with counsel for Respondents. Consistent

with Respondents' Response to Petitioner's Proffered Hearsay Evidence (Dck. # 170), Respondents do not oppose Petitioner's request to supplement the record with this additional declaration and does not oppose its admission. Respondents do not, however, believe that the declaration is material or relevant to the legality of Petitioner's detention and Respondents intend to address these deficiencies in the merits proceedings. 2. For the reasons stated in Petitioner's Unclassified Motion for Judgment on the

Record at ¶¶ (filed under seal, see Dcks. # 163 and 165 at 11), Petitioner maintains that the declaration is material and relevant to the legality of Petitioner's detention.

Dockets.Justia.com

WHEREFORE, Petitioner Barhoumi respectfully requests that this Motion be granted and that the Court permit Petitioner to supplement the record with the declaration attached hereto as Exhibit A. Dated: April 21, 2009 Respectfully submitted,

/s Danielle R. Voorhees Anne J. Castle Scott S. Barker J. Triplett Mackintosh William E. Murane Danielle R. Voorhees Meghan N. Winokur Nadya C. Bosch HOLLAND & HART LLP 555 Seventeenth Street, Suite 3200 Denver, CO 80202 Telephone: [phone] Facsimile: [phone]

CERTIFICATE OF SERVICE I hereby certify that on 4/21/2009, I electronically filed the foregoing with the Clerk of Court using the ECF system, which will send notification of such filing to the following: Judry Laeb Subar Terry Marcus Henry Jeanette Bead John Lohrer Andrew Warden Nicholas Andrew Oldham Timothy Laffredi [e-mail] [e-mail] [e-mail] [e-mail] [e-mail] [e-mail] [e-mail] /s Nadya C. Bosch Holland & Hart LLP

Holland & Hart LLP

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