IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 66

Unopposed MOTION for Protective Order by MOHAMMED ABDULLAH MOHAMMED BA ODAH, TARIQ ALI ABDULLAH BA ODAH, NASSER ALI ABDULLAH ODAH (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Text of Proposed Order granting unopposed motion for expedited entry of protective order)(Symon, Julia) Modified to add party filer on 7/16/2008 (tg, ).

IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Doc. 66

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA _______________________________________ IN RE: GUANTANAMO BAY DETAINEE LITIGATION ) ) ) ) ) ) ) ) ) ) Misc. No. 08-442 (TFH) Civil Action No. 1:06-cv-01668(HHK)

UNOPPOSED MOTION FOR EXPEDITED ENTRY OF PROTECTIVE ORDER Petitioners respectfully move for the expedited entry of the standard habeas protective orders, namely: (1) the Amended Protective Order and Procedures for Counsel Access to Detainees at the United States Naval Base in Guantanamo Bay, Cuba, first issued by this Court on November 8, 2004 (344 F. Supp. 2d 174 (D.D.C. 2004)); (2) the Order Addressing Designation Procedures for "Protected Information," first issued on November 10, 2004; and (3) the Order Supplementing and Amending Filing Procedures Contained in the November 8, 2004 Amended Protective Order, first issued on December 13, 2004, all in In Re Guantanamo Bay Detainee Cases (together, the "Protective Order"). See Exhibits 1-3.

NYA898644.2

Dockets.Justia.co

This motion is unopposed by the Respondents. Both Petitioners and Respondents reserve the right to seek modifications to the Protective Order and supplemental orders as appropriate in the future. Respondents' consent to this Motion is without prejudice to the aforementioned reservation. Dated: July 16, 2008

Respectfully submitted,

s/ Julia C. Symon (DC Bar No. 456828) CLIFFORD CHANCE US LLP 2001 K Street NW Washington, DC 20006 Tel: [phone] Fax: [phone] James M. Hosking CLIFFORD CHANCE US LLP 31 West 52nd Street New York, NY 10019 Tel: [phone] Fax: [phone] Counsel for Petitioners

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