IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 315

Consent MOTION for Entry of Protective Order by GUANTANAMO BAY DETAINEE LITIGATION, MOHAMMED ABDULMALIK (Attachments: # 1 Exhibit Amended Protective Order and Procedures for Counsel Access to Detainees at the United States Naval Base in Guantnamo Bay, Cuba, # 2 Exhibit Order Supplementing and Amending Filing Procedures Contained in November 8, 2004 Amended Protective Order, # 3 Exhibit Order Addressing Designation Procedures for Protected Information)(Katznelson, Zachary)

APPROVED FOR PUBLIC FILING BY CSO IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MOHAMMED ABDULMALIK, et al., ) ) Petitioners/Plaintiffs, ) ) v. ) ) GEORGE W. BUSH, et al., ) ) Respondents/Defendants. ) ________________________________________________)

Civ. No. 08-1440 (CKK) Misc. No. 08-442 (TFH)

CONSENT MOTION FOR ENTRY OF PROTECTIVE ORDER Petitioner Mohammed Abdulmalik respectfully moves the Court to enter the Amended Protective Order and Procedures for Counsel Access to Detainees at the United States Naval Base in Guantánamo Bay, Cuba, first issued on November 8, 2004 (344 F. Supp. 2d 174 (D.D.C. 2004)); the Order Supplementing and Amending Filing Procedures Contained in November 8, 2004 Amended Protective Order, first issued on December 13, 2004; and the Order Addressing Designation Procedures for "Protected Information," first issued on November 10, 2004, all in the In re Guantánamo Bay Detainee Cases by then Coordinating Judge Joyce Hens Green. 1 See Exhibits 1-3. Respondents consent to entry of these orders. Dated: August 29, 2008 Respectfully submitted, ______________________ Zachary Katznelson (California Bar No. 209489) 22 Tudor Street London EC4Y 0AY England Phone: [phone] Fax: [phone] E-mail: [e-mail] Counsel for Petitioners
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Mr. Abdulmalik and Respondents reserve the right to challenge or seek modification of any particular terms of the Amended Protective Order in the future.

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CERTIFICATE OF SERVICE I hereby certify that I have caused a copy of this Motion to be served upon counsel for Respondents by filing this document directly on ECF, pursuant to approval by the Court Security Officer.

Dated: August 29, 2008

_________________________________ Zachary Katznelson

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