IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 617

MOTION FOR IMMEDIATE RELEASE ON PAROLE INTO THE CONTINENTAL UNITED STATES PENDING FINAL JUDGMENT ON THEIR HABEAS PETITIONS by GUANTANAMO BAY DETAINEE LITIGATION (Tirschwell, Eric)

IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Doc. 617

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA : : : : : : : : Misc. No. 08-442 (TFH) 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. 05-2398 (RMU) Civil Action No. 08-1310 (RMU)

IN RE: GUANTANAMO BAY DETAINEE LITIGATION

MOTION OF ABDUL SABOUR, ABDUL NASSER, HAMMAD MEMET, EDHAM MAMET, ARKIN MAHMUD, BAHTIYAR MAHNUT, AHMAD TOURSON, ABDUR RAZAKAH, ANWAR HASSAN, DAWUT ABDUREHIM, ABDUL GHAPPAR ABDUL RAHMAN AND ADEL NOORI FOR IMMEDIATE RELEASE ON PAROLE INTO THE CONTINENTAL UNITED STATES PENDING FINAL JUDGMENT ON THEIR HABEAS PETITIONS Petitioners Abdul Sabour, Abdul Nasser, Hammad Memet, Edham Mamet, Arkin Mahmud, Bahtiyar Mahnut, Ahmad Tourson, Abdur Razakah, Anwar Hassan, Dawut Abdurehim, Abdul Ghappar Abdul Rahman and Adel Noori (collectively, the "Moving Uighur Petitioners") respectfully move for their immediate release on parole into the continental United States pending final judgment on their habeas petitions. On September 30, 2008, Respondents filed a notice of status as to the Moving Uighur Petitioners indicating that the government does not regard them as enemy combatants. Respondents previously conceded that they will afford the same treatment to Petitioners Huzaifa Parhat, Abdul Semet, Jalal Jalaldin, Khalid Ali and Sabir Osman. The Moving Uighur

Petitioners therefore join in the motion previously filed by Petitioner Parhat ­ and subsequently joined by Petitioners Semet, Jalaldin, Ali and Osman ­ for immediate release on parole. As grounds therefore, the Moving Uighur Petitioners rely on the previously submitted Declarations of Alim Seytoff and Rebia Kadeer and adopt and incorporate by reference as if fully set forth

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Dockets.Justia.com

herein the arguments articulated in Petitioner Parhat's memorandum of points and authorities in support of his motion for immediate release on parole into the continental United States pending final judgment on his habeas petition and memorandum of points and authorities in support of his motion for judgment ordering his release. The Moving Uighur Petitioners also request that their motion be heard at the upcoming status hearing on October 7, 2008. Dated: October 1, 2008 Susan Baker Manning Catherine R. Murphy BINGHAM McCUTCHEN LLP 1120 20th Street NW, Suite 800 Washington, DC 20036-3406 Telephone: [phone] Facsimile: [phone] Sabin Willett (Pursuant to LCvR 83.2(g)) Neil McGaraghan (Pursuant to LCvR 83.2(g)) Rheba Rutkowski (Pursuant to LCvR 83.2(g)) Jason S. Pinney (Pursuant to LCvR 83.2(g)) BINGHAM McCUTCHEN LLP One Federal Street Boston, Massachusetts 02110 Telephone: [phone] Facsimile: [phone] Counsel for Petitioners Abdul Nasser, Abdul Sabour, Abdul Semet, Hammad Memet, Jalal Jalaldin, Khalid Ali, Sabir Osman and Edham Mamet George Clarke MILLER & CHEVALIER CHARTERED 655 15th Street, NW, Suite 900 Washington, DC 20005 Telephone: [phone] Facsimile: [phone] Counsel for Petitioners Ali Mohammad and Thabid Respectfully submitted, /s/ Eric A. Tirschwell Eric A. Tirschwell (Pursuant to LCvR 83.2(g)) Michael J. Sternhell (Pursuant to LCvR 83.2(g)) Darren LaVerne (Pursuant to LCvR 83.2(g)) Seema Saifee (Pursuant to LCvR 83.2(g)) KRAMER LEVIN NAFTALIS & FRANKEL LLP 1177 Avenue of the Americas New York, New York 10036 Telephone: [phone] Facsimile: [phone] Counsel to Petitioners Abdul Razakah, Ahmad Tourson, Abdul Ghaffar and Adel Noori Elizabeth P. Gilson (Pursuant to LCvR 83.2(g)) 383 Orange Street New Haven, Connecticut 06511 Telephone: [phone] Facsimile: [phone] Counsel for Petitioners Bahtiyar Mahnut and Arkina Amahmud J. Wells Dixon (Pursuant to LCvR 83.2(g)) CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, New York 10012 Telephone: [phone] Facsimile: [phone] Counsel for All Uighur Petitioners

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