Filing 772

NOTICE of Filing of Emergency Motion for TRO by SAYF BIN ABDALLAH (Crider, Cori)

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) SAYF BIN ABDULLAH, et al. Petitioners, v. GEORGE W. BUSH, et al., Respondents. Misc. No. 08-442 (TFH) Civ. No. 05- 2386 (RBW) NOTICE OF FILING OF EMERGENCY MOTION FOR TEMPORARY RESTRAINING ORDER BARRING RESPONDENTS FROM TRANSFERRING PETITIONER TO TUNISIA Petitioner Sayf bin Abdullah (ISN 046), by his undersigned attorneys, hereby notifies the Court that on October 21, 2008, counsel filed with the Court Security Officer an Emergency Motion for Temporary Restraining Order Barring Respondents from Transferring Petitioner to Tunisia. He has not requested that the pleading be sealed. The Court's recent rulings on sealing have not specifically barred the government from sharing the contents of the underlying pleading--which specify his fears of persecution in Tunisia--with agents of the Tunisian government. As this obviates any benefit he stood to gain from sealing his motion, Petitioner prefers that the issues concerning, e.g., the prevalence of torture in Tunisia be aired in the open. Respectfully submitted, Dated: 21 October 2008 /s/ Cori A. Crider Zachary Katznelson, CA Bar No. 209489 Cori Crider, Member, New York Bar Ahmed Ghappour, CA Bar No. 255723 Reprieve PO Box 52742 London EC4P 4WS United Kingdom 011 44 207 353 4640 (ph) 011 44 207 353 4641 (fax) Joseph S. Berman, BBO NO. 566006 (admitted pursuant to Local Rule 83.2(g)) LOONEY & GROSSMAN, LLP 101 Arch Street, 9th Floor Boston, MA 02110 Tel: (617) 951-2800 Fax: (617) 951-2819 Counsel for Petitioner

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