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Motion to Supplement Record and Supp. Gosztola Declaration (March 4, 2013)

Motion to Supplement Record and Supp. Gosztola Declaration (March 4, 2013)

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Published by: maryroseeng on Mar 06, 2013
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1IN THE UNITED STATES COURT OF APPEALSFOR THE ARMED FORCES–––––––––––––––––––––––––––––––––– xCrim. App. Misc.Dkt. No. 20120514USCA Misc.Dkt. No. 12-8027/ARGeneral Court Martial
United States v. Manning
,Ft. Meade, MarylandDated: 4 March 2013CENTER FOR CONSTITUTIONAL RIGHTS,GLENN GREENWALD, JEREMY SCAHILL,
 THE NATION
, AMY GOODMAN,
DEMOCRACYNOW!
, CHASE MADAR, KEVIN GOSZTOLA, JULIAN ASSANGE, and WIKILEAKS,Appellants,v.UNITED STATES OF AMERICA and CHIEF JUDGE COL. DENISE LIND,Appellees.:::::::::::::::::–––––––––––––––––––––––––––––––––– x
MOTION TO SUPPLEMENT THE RECORD PURSUANT TO RULE 30 AND 30A
Pursuant to Rules 30 and 30A of this Courts Rules of Prac-tice and Procedure, Petitioner-Appellants in this matter herebysubmit thismotion to supplement the recordby submission of theattached
Supplemental Declaration of Kevin Gosztola
, a creden-tialed journalist covering the proceedings in
United States v.Manning
and a plaintiff in this matter. The supplemental decla-ration adds to his earlier declaration of May 23, 2012, andbrings to the attention of this Court further difficulties mem-bers of the press have had in covering the proceedings below inlight of the lack of public access to court orders and other
 
2records of the proceedings that have transpired since the oralargument held before this Court on October 10, 2012. The supplemental declaration also notes that the Army haspublished some of the orders of the trial court in redacted formpursuant to FOIA, and documents some of the shortcomings of those releases, as well as the fact that several categories o judicial documents Petitioner-Appellants seek here have stillnot yet been released to the public.Finally, the declaration notes that PFC Manning has pledguilty to some charges and, as to the rest, has waived jury tri-al in favor of a bench trial. As noted in the declaration, theabsence of a jury pool that might be contaminated by public re-lease of sensitive information should greatly simplify the pro-cessing of documents for public release by the trial court underthe First Amendment standard going forward.Good cause exists for this Court to grant this motion, asthe facts detailed in the supplemental declaration have arisensince the last briefing in this matter (the post-argument briefsfiled by the parties on October 22 and 31, 2012).Respectfully submitted,/s/sdkShayana Kadidal[C.A.A.F. Bar No. 35713]
 
3c/o Univ. of Michigan Law School
1
 625 S. State St.Ann Arbor, MI 48109 Tel: (646) 498-8498 J. Wells DixonBaher Azmy, Legal DirectorMichael Ratner, President EmeritusCENTER FOR CONSTITUTIONAL RIGHTS666 Broadway, 7th FloorNew York, New York 10012 Tel: (212) 614-6427Fax: (212) 614-6499 Jonathan Hafetz169 Hicks StreetBrooklyn, NY 11201 Tel: (917) 355-6896
Counsel for Petitioner-Appellants
 Dated: 4 March 2013
1
Institutional affiliation noted for identification purposesonly, and implies no endorsement by the University.

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