Plaintiffs’ Notice of Filing Additional Exhibits

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

______________________________________

CENTER FOR NATIONAL SECURITY
STUDIES, et al.,

Plaintiffs,

v.

DEPARTMENT OF JUSTICE,

Defendant.
_____________________________________

Judge Kessler

Civil Action No. 01-2500

NOTICE OF FILING ADDITIONAL EXHIBITS

I.

Plaintiffs’ Supplemental Memorandum, filed June 14, 2002, cited the district court decision in North Jersey Media Group, Inc. v. Ashcroft, __ F.Supp.2d __, 2002 WL 1163637 (D.N.J. May 28, 2002). Pl. Supp. Mem. at 6. Yesterday, the Third Circuit denied the government’s motion to stay that decision pending appeal. North Jersey Media Group, Inc. v. Attorney General, No. 02-2524 (3rd Cir. June 17, 2002). A copy of the court of appeals’ order is attached hereto as Exhibit A.

II.

On Saturday the Department of Justice officially released the name of another person detained by the INS in connection with the post-9/11 investigation. A Department spokeswoman announced the detainee’s name (Adham A. Hassoun), the date and place of his arrest (Miami on June 12), and his current place of detention ("outside Miami at Krome Detention Center"). The Department also disclosed the nature of his link to the investigation (Mr. Hassoun and Jose Padilla "knew each other in the 90’s and had attended a mosque together in Fort Lauderdale"). See Man Tied to Bomb Suspect is Arrested, New York Times, June 16, 2002 at A-10 (attached hereto as Exhibit B) (also available at <http://www.nytimes.com/2002/06/16/national/16ARRE.html>). These disclosures provide additional compelling evidence that the government’s arguments to this Court about the dangers of releasing the requested information are fatally undermined by the government’s own conduct.

Respectfully submitted,

______________________________
Arthur B. Spitzer, D.C. Bar. No. 235960
American Civil Liberties Union
of the National Capital Area
1400 20th Street, N.W. #119
Washington, D.C. 20036
Tel. 202-457-0800
Fax 202-452-1868

Kate Martin, D.C. Bar No. 949115
Center for National Security Studies
1120 19th St., N.W. 8th floor
Washington, D.C. 20036
Tel. 202-994-7060
Fax 202-994-7005

David L. Sobel, D.C. Bar No. 360418
Electronic Privacy Information Center
1718 Connecticut Avenue, N.W. #200
Washington, DC 20009
Tel. 202-483-1140
Fax 202-483-1248

Steven R. Shapiro
Lucas Guttentag
American Civil Liberties Union Foundation
125 Broad Street
New York, N.Y. 10004
212-549-2500

Elliot M. Mincberg, D.C. Bar No. 941575
People For the American Way Foundation
2000 M Street N.W., Suite 400
Washington, D.C. 20036
Tel. 202-467-4999
Fax 202-293-2672

June __, 2002 Counsel for Plaintiffs

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