IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 515

NOTICE of Supplemental Authority, Witness Disclosure, and Report on Client Authorizations by JAMAL KIYEMBA (Attachments: # 1 Appendix Exhibit List, # 2 Exhibit A, # 3 Exhibit Decision of CADC, # 4 Exhibit B, # 5 Exhibit Gov's Motion to Apply Parhat, # 6 Exhibit C, # 7 Exhibit Florida Uighur Resettlement Plan, # 8 Exhibit D, # 9 Exhibit Adem Decision, # 10 Exhibit E, # 11 Exhibit, # 12 Declaration Jason S. Pinney, # 13 Exhibit, # 14 Declaration Elizabeth P. Gilson, # 15 Errata, # 16 Declaration Kramer Levin, # 17 Declaration Kramer Levin, # 18 Declaration Kramer Levin, # 19 Declaration Kramer Levin, # 20 Exhibit, # 21 Declaration George Clarke)(Gilson, Elizabeth)

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Misc. No. 08-442 (TFH) IN RE: GUANTANAMO BAY DETAINEE LITIGATION Civil Action No. 05-1509 (RMU) Civil Action No. 05-1602 (RMU) Civil Action No. 05-1704 (RMU) Civil Action No. 05-2370 (RMU) Civil Action No. 05-2386 (RMU) Civil Action No. 05-2398 (RMU) DECLARATION OF JASON S. PINNEY I, Jason S. Pinney, hereby declare under penalty of perjury that the following facts are true and accurate to the best of my knowledge and belief: 1. 2. I am an attorney with Bingham McCutchen LLP. My principal work address is One Federal Street, Boston, MA 02110. DIRECT ORAL REPRESENTATION AUTHORIZATIONS Petitioner Hammad Mehmet 3. Hammad Mehmet (ISN 328) is a Uyghur prisoner held at the U.S. Naval Station at Guantdnamo Bay, Cuba. 4. On July 29, 2005, Bingham McCutchen filed a habeas corpus petition on Petitioner Mehmet's behalf based on the next friend authorization provided by Jamal Kiyemba, dated March 10, 2005. A copy of that authorization is attached as Exhibit Al. 5. On December 4, 2006, Bingham McCutchen filed a petition under the Detainee Treatment Act of 2005 on Petitioner Mehmet's behalf. I Bingham McChutchen has also obtained authorization to represent Petitioner Mehmet from his brother. 6. In January of 2007, during a meeting with Petitioner Mehmet, I prepared a declaration, which was witnessed by Ms. Rushan Abbas, a Uyghur translator who accompanied me during the meeting. A copy of the declaration is attached as Exhibit B. 7. As set forth in the declaration, Petitioner Mehmet orally authorized Bingham McCutchen to represent him as counsel in all actions in order to secure his release from Guantanamo Bay. Petitioner Mehmet indicated that he was not willing to sign a declaration himself because he does not have faith in the legal system, and because he is wary of signing documents. Petitioner Jalal Jalaldin 8. Jalal Jalaldin (ISN 285) is a Uyghur prisoner held at the U.S. Naval Station at Guantanamo Bay, Cuba. 9. On July 29, 2005, Bingham McCutchen filed a habeas corpus petition on Petitioner Jalaldin's behalf based on the next friend authorization provided by Jamal Kiyemba, dated March 10, 20052. 10. On December 4, 2006, Bingham McCutchen filed a petition under the Detainee Treatment Act of 2005 on Petitioner Jalaldin's behalf. 11. In January of 2007, during a meeting with Petitioner Jalaldin, I prepared a declaration, which was witnessed by Ms. Rushan Abbas, a Uyghur translator who accompanied me during the meeting. A copy of the declaration is attached as Exhibit C. 12. As set forth in the declaration, Petitioner Jalaldin orally authorized Bingham McCutchen to represent him as counsel in all actions in order to secure his release from Guantanamo Bay. 2 Bingham McCutchen has also obtained authorization to represent Petitioner Jalaldin from his sister and brother-in-law. 2 A/72662406.1/0999997-0000928706 Petitioner Jalaldin indicated that he was not willing to sign a declaration himself because he does not have faith in the legal system, and because he is wary of signing documents. Petitioner Abdul Nassir 13. Abdul Nassir (ISN 278) is a Uyghur prisoner held at the U.S. Naval Station at Guantanamo Bay, Cuba. 14. On July 29, 2005, Bingham McCutchen filed a habeas corpus petition on Petitioner Nassir's behalf based on the next friend authorization provided by Jamal Kiyemba, dated March 10, 2005. 15. On March 13, 2007, Bingham McCutchen filed a petition under the Detainee Treatment Act of 2005 on Petitioner Nassir's behalf. 16. In January of 2007, during a meeting with Petitioner Nassir, my colleague Sabin Willett prepared a declaration, which was witnessed by Ms. Rushan Abbas, a Uyghur translator who accompanied Mr. Willet during the meeting. A copy of the declaration is attached as Exhibit D. 17. As set forth in the declaration, Petitioner Nassir orally authorized Bingham McCutchen to represent him as counsel in all actions in order to secure his release from Guantanamo Bay. Petitioner Nassir indicated to Mr. Willett that he was not willing to sign a declaration himself. Petitioner Khalid Ali 18. Khalid Ali (ISN 280) is a Uyghur prisoner held at the U.S. Naval Station at Guantanamo Bay, Cuba. 19. On July 29, 2005, Bingham McCutchen filed a habeas corpus petition on Petitioner Ali's behalf based on the next friend authorization provided by Jamal Kiyemba, dated March 10, 2005. 20. On December 4, 2006, Bingham McCutchen filed a petition under the Detainee Treatment Act of 2005 on Petitioner Ali's behalf. 3 A/72662406.1/0999997-0000928706 21. In January of 2007, during a visit with Petitioner Ali, my colleague Sabin Willett prepared a declaration, which was witnessed by Ms. Rushan Abbas, a Uyghur translator who accompanied Mr. Willet on the visit. A copy of the declaration is attached as Exhibit E. 22. As set forth in the declaration, Petitioner Ali orally authorized Bingham McCutchen to represent him as counsel in all actions in order to secure his release from Guantanamo Bay. Petitioner Ali indicated to Mr. Willett that he was not willing to sign a declaration himself because he cannot trust American documents. DIRECT WRITTEN REPRESENTATION AUTHORIZATIONS Petitioner Huzaifa Parhat 23. Huzaifa Parhat (ISN 320) is a Uyghur prisoner held at the U.S. Naval Station at Guantanamo Bay, Cuba. 24. Attached as Exhibit F is a true and correct copy of a letter signed by Huzaifa Parhat directly authorizing Bingham McCutchen to represent him. Petitioner Sabir Osman 25. Sabir Osman (ISN 282) is a Uyghur prisoner held at the U.S. Naval Station at Guantanamo Bay, Cuba. 26. Attached as Exhibit G is a true and correct copy of a letter signed by Sabir Osman directly authorizing Bingham McCutchen to represent him. Petitioner Abdul Semet 27. Abdul Semet (ISN 295) is a Uyghur prisoner held at the U.S. Naval Station at Guantanamo Bay, Cuba. 28. Attached as Exhibit H is a true and correct copy of a translated letter from Petitioner Semet directly authorizing Bingham McCutchen to represent him. Portions of the letter have 4 A/72662406.1/0999997-0000928706 been redacted based on privilege concerns. There is nothing in the redacted sections suggesting that Petitioner Semet does not want Bingham McCutchen to represent him. Verification I declare under penalty of perjury that the foregoi,pg is true and correct. Executed on September 0, 2008. 5 A/72662406.1/0999997-0000928706 EXHIBIT A f !mkt Z-02-- :.,^^^Z^ tvMcNt? A-1 ^rYt tom"; cl l> ^V4 . i7 zN( A 1-- t a tsTTf -rat C-A-vc 1: 'L f rr; ff .t"=`^"t ,-101... CiII NA:tuz- t'.-%334::51k 4^-%-D 4 I V ,- t Y .'t AN i,-- r ,Pt 9:" ti t Ii _C 4. [\'V. i:, V -v F1 r`: ;6 4. i' N f\ EXHIBIT B P. 14 11 I W vt 4 WY 4) 0Q FEB-15-200? 13-15 P.1 IA t if EXHIBIT C FEB-15-2 ? 13:19 P.29 IC -1 ;la wW 1-7f M -:t' ^ IQ 0^ FLy V U, /4, N't S! A4.e 02'd EXHIBIT D 4 e c i atc- Q '\4*U -t"l 04 Nt^ 2, 78 '` c. 0-6 : ^p s ovj -F, to 0 re- to a4,t P) rs,r d",q . a^n S P, 17,07 ^' i 0 n f^ r EXHIBIT E L CtJv * !i L psua wt om ws v-k- itA- ETA pt4i aAA, E,1 c. 3 Al\ C&,%P t3u aA f%. r, wj t- EXHIBIT F 5 LL C/ EXHIBIT G U a'{ r " ela O-ce3 S 4, e t h, A/0 V. EXHIBIT H FOR OFFICIAL USE ONLY } - 7rt^t3r ^' 1, 2006 Dear Nile. Sabi n Willet, Ifc v , are yoO 1 received three letters from you and thank you eery mur-h for oiler represent me. For that, I wn grateful to you and your colleagues. REDACT ED FOR OFFI CIAL USE ONLY REDACTED ho-vv to pay back people's kindness and e out of this ordeal. I know wt udd si eere; appreciate anyone vdio call get c ur ColleagtICS J'() t tiz .t ..1(^ t^j t Je 1c ;,; , J)aI is and Lastly, I rL ;i cif .liv a lp <3 } all , the procedures that the US mllitazrv trilxumt l folk ve(i in deter iimrIg r , S.i'Mltes for Ward I '111 Cagerly enemy carnlaaumnt. f molly hope, this letter will fin d YOu to hearing back fron-i you. ly yours, FOR OFFICIAL USE ONLY 7

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