Al Shimari v. Dugan et al

Filing 46

Statement of Undisputed Facts by CACI International, Inc, CACI Premier Technology, Inc. (Koegel, Joseph)

Al Shimari v. Dugan et al

Doc. 4

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA ALEXANDRIA DIVISION ____________________________________ SUHAIL NAJIM ABDULLAH AL SHIMARI, et al., Plaintiffs, v. CACI INTERNATIONAL INC, et ano, Defendants. ) ) ) ) ) ) ) ) ) ) ) )

Case No. 1:08-CV-00827-GBL-JFA

STATEMENT OF MATERIAL FACTS FOR WHICH THERE IS NO GENUINE DISPUTE IN CONNECTION WITH THE MOTION OF DEFENDANTS CACI PREMIER TECHNOLOGY, INC., AND CACI INTERNATIONAL INC FOR PARTIAL SUMMARY JUDGMENT BASED ON THE STATUTE OF LIMITATIONS Defendants CACI Premier Technology, Inc., and CACI International Inc hereby submit the following Statement of Material Facts For Which There Is No Genuine Dispute in connection with their motion for partial summary judgment based on the statute of limitations: 1. Plaintiff Rashid alleges that he was arrested by United States military personnel

on or about September 22, 2003, and released on or about May 6, 2005. Am. Compl. ¶¶ 26, 44. 2. Plaintiff Al Zuba'e alleges that he was arrested by United States military

personnel on or about November 1, 2003 and released on or about October 24, 2004. Am. Compl. ¶¶ 45, 53. 3. Plaintiff Al-Ejaili alleges that he was arrested by the United States military on or

about November 3, 2003 and released on or about February 1, 2004. Am. Compl. ¶¶ 54, 63.

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Plaintiffs Rashid, Al Zuba'e, and Al-Ejaili allege that they suffered the personal

injuries for which they seek to hold the CACI Defendants liable during the time that they were detained by the United States military at Abu Ghraib prison in Iraq. Am. Compl. ¶ 1. 5. This action was first filed as a single-Plaintiff lawsuit by Plaintiff Al Shimari on

June 30, 2008. Compl. (filed June 30, 2008). This motion does not seek summary judgment on Plaintiff Al Shimari's claims. 6. Plaintiffs Rashid, Al Zuba'e, and Al-Ejaili first filed claims against the CACI

Defendants in the United States District Court for the Eastern District of Virginia on September 15, 2008 when they, along with Plaintiff Al Shimari, filed an Amended Complaint in this Court. Am. Compl. (filed September 15, 2008). Respectfully submitted, /s/ J. William Koegel, Jr. J. William Koegel, Jr. Virginia Bar No. 38243 John F. O'Connor (admitted pro hac vice) Attorneys for Defendants CACI Premier Technology, Inc. and CACI International Inc STEPTOE & JOHNSON LLP 1330 Connecticut Avenue, N.W. Washington, D.C. 20036 [phone] - telephone [phone] ­ facsimile [e-mail] [e-mail]

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CERTIFICATE OF SERVICE I hereby certify that on the 10th day of October, 2008, I served the foregoing, by hand delivery, on the counsel indicated below. In addition, I will electronically file the foregoing with the Clerk of Court using the CM/ECF system, which will then send a notification of such filing (NEF) to the following: Susan L. Burke William Gould Attorneys for Plaintiff Burke O'Neil LLC 4112 Station Street Philadelphia, PA 19127 [phone] ­ telephone [e-mail] [e-mail] /s/ J. William Koegel, Jr. J. William Koegel, Jr. Virginia Bar No. 38243 Attorney for Defendant CACI-Athena, Inc. STEPTOE & JOHNSON LLP 1330 Connecticut Avenue, N.W. Washington, D.C. 20036 [phone] - telephone [phone] ­ facsimile [e-mail]