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 x IN RE: GUANTANAMO BAY DETAINEE LITIGATION x ABDUR RAZAKAH, et al., Petitioners, v. GEORGE W. BUSH, et al., Respondents. x DECLARATION OF J. WELLS DIXON I, J. WELLS DIXON, pursuant to 28 U.S.C. § 1746, declare as follows: 1. am an attorney at the Center for Constitutional Rights, 666 Broadway, 7th Floor, ivil Action No. 05-2370 (RMU) Misc. No. 08-442 (TFH)

New York, New York 10012 ("CCR"). Along with Kramer Levin Naftalis & Frankel LLP ("Kramer Levin"), CCR is counsel to Petitioner Ahmad Tourson ("Petitioner") in the abovecaptioned habeas case. 2. have met with Petitioner at the U.S. Naval Station at Guantanamo Bay, Cuba

("Guantanamo") on multiple occasions between July 2006 and February 2008. As set forth in my declaration filed in a related Uighur case more than two years ago, during these meetings Petitioner directly authorized me and my co-counsel at Kramer Levin to represent him and obtain his release from Guantanamo. See Ex. 1, ¶ 7 (attached hereto).

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etitioner also directly authorized our representation in writing. For instance,

Petitioner wrote a letter to me in January 2007, more than a year and a half ago, acknowledging and accepting our representation. An English translation of that letter was prepared by a Uighurlanguage interpreter, and is attached hereto in redacted form. The translation is redacted to omit privileged and confidential attorney-client communications. 4.
See Ex.

2 (attached hereto).

n any case, since my co-counsel and I first met with Petitioner in Guantanamo in

July 2006, the government has not challenged our authority to represent him. Nor is there any basis to do so now. Any question whether Petitioner wants to pursue habeas relief after more than six years of indefinite detention was settled long ago. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. xecuted: ew York, New York September 23, 2008 SS

EXHIBIT 1

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA x AMER MOHAMMON, et at, Petitioners, v. GEORGE W. BUSH, etat, Respondents. x No. 05 CV 2386 (RBW) (AK)

DECLARATION OF.1. WELLS DIXON I, J. WELLS DIXON, pursuant to 28 U.S.C. § 1746, declare as follows: 1. I am an attorney at the Center for Constitutional Rights, 666 Broadway,

7th Floor, New York, New York 10012 ("CCR"). CCR is co-counsel to all petitioners in the above-captioned case. I am licensed to practice law in the States of New York and Colorado. 2. I am also employed by Kramer Levin Naftalis & Frankel LLP, 1177

Avenue of the Americas, New York, New York 10036 ("Kramer Levin"), and am currently on a leave of absence from that firm to work at CCR. Kramer Levin represents Petitioners Abdul Rahman a/lc/a Abdul Ghaffar (ISN 281) and Adel LNU a/k/a Adel Noori (ISN 584) ( "Petitioners " ) in the above-captioned case. I respectfully submit this declaration in support of Petitioners' renewed motion for access to their counsel and related relief, filed in response to Respondents ' July 26, 2006 status report.

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3.

Kramer Levin also represents, as co-counsel with CCR, the three

petitioners in Mamet v. Bush, No. 05 CV 1886 (EGS), and the two petitioners in Razakah v. Bush, No. 05 CV 2370 (EGS). 4. Like the Mama and Razakah petitioners, Petitioners here are citizens of

the Xinjiang Autonomous Region, a western province of China also commonly referred to as " Turkistan " or "East Turkistan. " They are Uighurs, a Turkic Muslim minority group that has been brutally oppressed by the communist Chinese government. 5. I am informed and believe that there have been a total of twenty-two

Uighurs from China detained by Respondents at the U.S. Naval Station at Guantanamo Bay, Cuba ("Guantanamo"). At the time that I appeared in this case on behalf of Petitioners, those two detainees were the only two Uighurs from China not represented by counsel. Indeed, apart from Petitioners here, all of these men have been positively identified by Respondents as detainees at Guantanamo and have been granted access to their counsel. 6. I am further informed and believe that nineteen of the twenty-two Uighur

detainees appear on the next-friend authorization of Usama Hasan Abu Kabir (the "Kabir Authorization " ). They are each identified on the Kabir Authorization by a single name or alias. They are also identified as "Turkestani, " which again means that they are Uighurs from China. 7. I recently traveled to Guantanamo to meet with the Razakah petitioners.

In particular, I met with Razakah petitioner Ahmad Turson (ISN 201) for three days between July 24 and 28, 2006. Mr. Turson appears on the Kabir Authorization, which I reviewed with him. Mr. Turson confirmed that the Kabir Authorization is correct and that he wants counsel to represent him and obtain his release from Guantanamo.

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8.

We also discussed the other Uighur detainees from China who are Mr. Turson confirmed that:

identified on the Kabir Authorization, including Petitioners here.

(a) the Uighur detainee identified on the Kabir Authorization as " Abdul Rahman" from `Turkistan[ J" is also known as "Abdul Ghaffar"; (b) the Uighur detainee identified on the Kabir Authorization as "Adel" from "Turkistan[ ]" is "Adel Noori"; and (c) the only other Uighur detainee ever held at Guantanamo named "Adel" is Adel Abdu Al Hakim, who was released to Albania in May 2006. . am further informed and believe that Adel Abdu Al Hakim is also known

as " Mohammed " from Turkistan. 10. Adel Abdu Al Hakim and Abu Bakker Qassim were petitioners in Qassim

v. Bush, No. 05-5477 (D.C. Cir.). They were released with the Mamet petitioners to Albania on or about May 5, 2006. I have spoken with the Marne: and Qassim petitioners by telephone on several occasions since their release to Albania. Like Mr. Turson, they have confirmed that:

(a) the Uighur detainee known as " Abdul Rahman" is also known as " Abdul Ghaffar" ; and (b) there were only two Uighur detainees at Guantanamo named "Adel" -- Adel Abdu Al Hakim and Petitioner Adel Noori. 11. The Mamet and Qassim petitioners have also confirmed that: (a) Petitioner

Abdul Ghaffar was captured with them by privateers in Pakistan, and they were sold to the United States for a bounty of $5,000 each; and (b) Petitioner Adel Noori was likewise captured in Pakistan. 2. am also informed and believe that Petitioners are each from an area of

Turkistan near the city of Kucha.

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I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.

Executed:

ew York, New York September 11, 2006

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Mr. Wells Dixon, Redacted How are you? his is my first letter to you since we have been in contact with you and your legal firm. You have been working hard on our behalf in order to prove our innocence. You have been doing all of this without getting paid and utilizing the legal systems in an effort to free us from being detained here. We want to inform you of our gratitude and appreciation for your hard work. We really don't have anything else to give you other than our "Thanks". Please also give our greetings to your other colleagues as well.

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We apologize for asking so much from you at this time but are deeply thankful for your efforts.

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Sincerely, Ahmet Tursun (201) January 23, 2007.

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