Guantanamo Bay Hunger Strike Lawsuit

Guantanamo Bay hunger strike lawsuit

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Guantanamo Bay Hunger Strike Lawsuit

Guantanamo Bay hunger strike lawsuit

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crecente7032

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Case 1:05-cv-01457-UNA Document 226 Filed 05/23/14 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

ABU WAEL (JIHAD) DHIAB (ISN 722),

Petitioner,
Civil Action No. 05-CV-1457 (GK)
v.
BARACK H. OBAMA, et al.,
Respondents.

RESPONDENTS NOTICE OF FILING OF PUBLIC VERSIONS OF

RESPONDENTS AND PETITIONERS BRIEFS RELATED TO PETITIONERS
APPLICATION FOR PRELIMINARY INJUNCTION
In accordance with the representation made by Respondents counsel during the
Status Conference held in the above-captioned case on May 21, 2014, and pursuant to the
Protective Order & Procedures for Counsel Access to Detainees at the United States
Naval Base in Guantanamo Bay, Cuba (Sep. 11, 2008) (ECF No. 57) (Protective
Order), Respondents hereby provide the Court and Petitioner, and file on the docket,
public versions of the following briefs:

Petitioners Supplemental Memorandum In Support Of Petitioners Application

For Preliminary Injunction (filed under seal on April 18, 2014) (ECF No. 208);

Respondents Opposition To Petitioners Application For A Preliminary Injunction

(filed under seal on May 7, 2014) (ECF No. 214);

Petitioners Reply Memorandum In Support of Petitioners Application For

Preliminary Injunction (May 12, 2014) (ECF No. 215).

Case 1:05-cv-01457-UNA Document 226 Filed 05/23/14 Page 2 of 3

See Exhibits 1-3.1 The unredacted versions of these briefs were filed under seal because
they contained information designated as protected information by the Government.
See Protective Order I.B.10 (defining protected information) & I.E.49 (authorizing
under seal filing of documents containing protected information). The attached public
versions have been redacted to shield that protected information.
As the Protective Order contemplates, the parties still need to confer regarding the
redacted versions of the attached briefs to determine whether Petitioner objects to any of
the redactions. See Protective Order I.E.34. Once Petitioner notes his objections, if
any, Respondents suggest that the parties propose a briefing schedule to the Court so that
the matter may be properly presented for decision. See id.

Dated: May 23, 2014

Respectfully submitted,
STUART F. DELERY
Assistant Attorney General
JOSEPH H. HUNT
Branch Director
TERRY M. HENRY
Assistant Branch Director
/s/ Andrew I. Warden
ANDREW I. WARDEN (IN Bar 23840-49)
TIMOTHY B. WALTHALL
PATRICK D. DAVIS
United States Department of Justice
Civil Division, Federal Programs Branch
20 Massachusetts Avenue, NW

Respondents note that public versions of corresponding documents pertaining to the nearly identical
preliminary-injunction applications filed in two other cases, Hassan v. Obama, Civ. Action No. 04-1194
(TFH), and Rabbani v. Bush, Civ. Action No. 05-1607 (RCL) shortly will be filed on the public docket in
those cases. To the extent further litigation ensues regarding the propriety of the redactions in the public
versions of the documents filed in this case, Hassan, and Rabbani, see infra, the Court should coordinate
such litigation between the cases so as to promote efficient use of the Courts and parties resources, as well
as prevent potentially inconsistent rulings in the cases regarding the appropriate public versions of the same
information and materials.