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)

EXHIBIT C
FLORIDA UIGHUR RESETTLEMENT PLAN Wednesday, September 24, 2008 THE STEERING COMMITTEE The operational responsibility for resettlement and monetary disbursements will be handled by a committee. Membership 1. Chair. Salah Bakhashwin, member of the Shura Council (governing body) of the Islamic Center of Tallahassee. Secretary. Kent Spriggs, experienced Guantánamo habeas counsel (but not for any of the Uighurs). Liaison with the counsel for the Uighurs and person with a knowledge of the context of the Uighurs at Guantánamo and who is in a position to spend as much time as is necessary on the resettlement project. Rev. John Lown, Pastor of Lafayette Presbyterian Church who has three years of full-time experience in refugee resettlement working with the federal government in Northern Virginia. Rev. Brant Copeland, Pastor of First Presbyterian Church, Cochair of the Tallahassee Interfaith Clergy, which will tie in a wider faith community. See "Wider Support Group." A member of the congregation of the Nasjid A- Nahl mosque.

2.

3.

4.

5.

Fundamental roles

1

a. Money ­ raising money (a task shared with the Wider Support Group) and disbursement. b. Day to day liaison with the men on all elements of resettlement discussed below.

Money a. Fund-raising and custodian

i. Central financial repository. First Presbyterian Church performed function this citywide for Katrina. They have set up a separate account following the bookkeeping procedures previously used, so there is no learning curve. The current balance is $4500. ii. Other tax-exempt conduits to feed into the central repository, e.g., Presbyterians, Temple Israel, Quakers, UU, UCC, Methodists. See Wider Support Group, below. b. Disbursement. The Steering Committee would approve major expenditures and give instructions to First Presbyterian. A subset of the Committee will approve lesser expenditures.

Non-monetary Components of the Day to Day Realities Spiritual home The Islamic Center of Tallahassee Housing The Committee has secured an appropriate apartment near public transportation and the Islamic Center. Furnishings will be donated and bought.

2

Cell phones will be provided to each of the men (ID card necessary or lend phones of others) Jobs The Committee has firm job offers for the three men at Bianca Restaurants owned by a member of the Islamic Center. These will be jobs that require modest English and working skills until we know the skill levels and interests of the men. Eventually men can decide on what is a good fit of a job based on more refined skill sets, if any. Committee will deal with legal issues related to employment. The U.S. Parole Office will be of assistance in this working with INS. Transportation i. Initially public transport and ii. Volunteer supporters will supplement public transportation. A Welcome and Transportation Committee will be made up of persons who volunteer from the mosques, churches, and the synagogue. b. Self-sufficiency a.

Establish driving skills of one or more of the men. U.S. Parole Office will assist in obtaining identification so that one or more of the men can obtain drivers' license(s). Committee will assist in getting licensed. When drivers' permits are obtained, the Committee will buy a used car. Committee will pay for automobile insurance. Health Checkup by doctor and dentist and provision for care. This will be donated and/or financed by the Committee.
3

Psychological assessment is recommended if the language barrier can be handled.

Language training Instruction in English as second language. Tutors or program. General social integration The Welcome and Transportation Committee will take responsibility for integrating the men into the community. E.g., learning how to shop, structuring opportunities to get out and about, etc. The men will be given "hot lines" on their cell phones to a limited number of persons who will be available 24/7 to deal with problems not anticipated.

THE WIDER SUPPORT GROUP The organization already in place which can reach the greatest number of persons in the shortest time is the Tallahassee Interfaith Clergy. A substantial part of this is already in place in that a number of religious leaders have signed on as of this writing. The functions of the wider support group are: 1. Dissemination of knowledge of the project. Education of congregations has commenced. 2. Public endorsement of the project and welcome on behalf of circa 15 communities of faith. 3. Money-raising. Substantial money has been raised that effort is just beginning.

4

4.

Responding to "wish lists," e.g., furniture for dwelling.

5. Provide some of the persons for the Welcome and Transportation Committee.

5