IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 349

Emergency MOTION for Leave to File Supplemental Declaration in Support of Emergency Motion to Compel Access to Medical Records and For Other Miscellaneous Relief by ADNAN FARHAN ABDUL LATIF (Attachments: # 1 Exhibit)(Falkoff, Marc)

CLEARED FOR PUBLIC FILING BY THE COURT SECURITY OFFICER

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) )

IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Misc. No. 08-0442 (TFH) Civil Action No. 04-1254 (HHK)

EMERGENCY MOTION FOR LEAVE TO FILE SUPPLEMENTAL DECLARATION IN SUPPORT OF EMERGENCY MOTION TO COMPEL ACCESS TO MEDICAL RECORDS OF PETITIONER ADNAN FARHAN ABDUL LATIF AND FOR OTHER MISCELLANEOUS RELIEF Petitioner Adnan Farhan Abdul Latif respectfully asks leave to file the attached supplemental declaration of counsel (Ex. 1) in support of his emergency motion to compel access to his medical records. On September 5, 2008, Mr. Latif again attempted suicide at Guantánamo, this time by biting off and swallowing ten inches of the plastic tube that was being used to force-feed him. This new information is relevant to the pending motion. The events described in the attached Second Declaration of Mark D. Falkoff provide further reason for this Court to allow counsel access to Mr. Latif's medical records. Respondents take no position on the motion. Respectfully submitted, /s/ _____________________ Marc D. Falkoff D.C. Bar No. 491149 NORTHERN ILLINOIS UNIVERSITY COLLEGE OF LAW DeKalb, IL 60614 347-564-5043 (cell) 815-753-9301 [e-mail] Counsel for Petitioner Dated: September 8, 2008