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The documents in this section contain the major filings with regard to a Freedom of Information Act lawsuit filed by The Center for National Security Studies on behalf of 20 plaintiffs, including my website publication The Multiracial Activist, which joined the suit on December 10, 2001.
- Original
Complaint, filed December 6, 2001
- Amended
Complaint, filed December 10, 2001
- Department
of Justice Answer, filed January 11, 2002
- Department of Justice Motion for Summary
Judgment and supporting documents
- Motion
for Summary Judgment
- Memorandum
in Support of Motion
- Statement
of Facts
- James
Reynolds Affidavit, Chief,
Terrorism and Violent Crime Section, Criminal Division, DOJ
- Melanie
Ann Pustay Affidavit, Deputy Director, Office of Information and Privacy,
DOJ
- Raymond
Holmes Affidavit, Acting Chief, Freedom of Information and Privacy
Acts Operations Unit, INS
- Scott
Hodes Affidavit, Acting Chief, Freedom of Information and Privacy
Acts Operations Unit, FBI
- Information on detainees released by
the Department of Justice in connection with its filing, January 11, 2002
- Plaintiff's Motion to Stay Proceedings
on Defendant's Summary Judgment Motion Pending Discovery and supporting documents,
January 22, 2002
- Department of Justice's Opposition to
Plaintiff's Motion to Stay Proceedings on Defendant's Summary Judgment Motion
Pending Discovery and supporting documents, February 5, 2002
- Plaintiff's
Reply in Support of Motion to Stay Proceedings on Defendant's Summary
Judgment Motion Pending Discovery, February 12, 2002.
- Plaintiff's Requests for Discovery, February 12, 2002
- Judge
Kessler's Opinion on Plaintiffs' Motion for Discovery, February 21, 2002
- Plaintiffs' Cross-Motion for Summary
Judgment, March 18, 2002
- Department of Justice's Reply to Plaintiff's
Cross-Motion for Summary Judgment, April 15, 2002
- Defendant's
Reply in Support of Motion for Summary Judgment and Opposition to Plaintiff's
Motion for Summary Judgment
- Defendant's
Objections and Responses to Plaintiffs' Statement of Material Facts
- Dale
L. Watson Affidavit, Executive Assistant Director for Counterterrorism
and Coutnerintelligence, FBI
- Melanie
Ann Pustay Affidavit, Deputy Director, Office of Information and Privacy,
DOJ
- Supplemental
Affidavit of Scott A. Hodes, Acting Chief, Freedom of Information
and Privacy Acts Operations Unit, FBI
- Second
Supplemental Affidavit of James S. Reynold, Chief, Terrorism and Violent
Crime Section, Criminal Division, DOJ
- Supplemenatl
Affidavit of Raymond Holmes, Acting Chief, Freedom of Information
and Privacy Acts Operations Unit, INS
- Amicus
Brief of the Washington Legal Foundation in Support of the Department
of Justice, April 15, 2002
- Plaintiffs'
Reply in Support of their Cross-Motion for Summary Judgment and Opposition
to Defendant's Mortion for Summary Judgment, April 30, 2002
- Oral
Argument before Judge Gladys Kessler, May 29, 2002
- Assistant Attorney General Robert
McCallum and Anne Weisman, for Defendants
- Kate Martin, Director of the Center
for National Security Studies, for Plaintiffs
- At the invitation of the Court:
- Plaintiffs'
Notice of Filing Additional Exhibits, June 20, 2002
- Plaintiffs'
Second Notice of Filing Additional Exhibits, June 28, 2002
- JUDGE
KESSLER'S DECISION, August 2, 2002
- Defendant's Motion to Stay Decision Pending
Appeal, August 8, 2002
- Plaintiffs'
Opposition to Defendant's Motion to Stay Decision Pending Appeal, August
13, 2002
- Brief
for Appellant, On Appeal for the United States District Court of the District
of Columbia, September 20, 2002
- Brief for
Appellees/Cross-Appellants in the United States Court of Appeals for the District
of Columbia Circuit, Tuesday, October 15, 2002
- Amicus
Brief of The Washington Post Company, et al., in support of Appellees/ Cross-Appellants,
October 18, 2002
- Reply
Brief for Appellant and Brief for Cross-Appellee,
November 4, 2002
- Reply
Brief for Cross-Appellants, November 8, 2002
- Letter
to Court of Appeals Calling Attention to the release of new IG report on Post
9/11 detainees, June 4, 2003
- D.C.
Circuit Appeals Court Decision, Opinion for the Court filed by Judge Sentelle
and Dissent filed by Judge Tatel, June 17, 2003
- Plaintiff's Cert Petition filed in the United States Supreme Court, September 29, 2003 (docket number 03-472)
- Media organizations file Amici Curiae
brief in support of cert, October 30, 2003 (docket number 03-472)
- Government's Opposition to Cert, December 12, 2003 (docket number 03-472)
- Plaintiff's Reply Brief to Government's Opposition, December 22, 2003 (docket number 03-472)
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