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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
______________________________________
)
CENTER FOR NATIONAL SECURITY STUDIES, )
ET AL., )
Plaintiffs, )
)
v. ) Civil Action
) No. 01-2500
UNITED STATES DEPARTMENT OF JUSTICE, )
) Judge Kessler
Defendant. )
______________________________________)
DEFENDANT'S NOTICE OF FILING OF AMENDED AND SUPPLEMENTAL EXHIBITS
Defendant hereby submits the attached amended Exhibits 5-6, and supplemental
Exhibits 7-11, which are intended to accompany Defendant's Motion for Summary
Judgment.
Amended Exhibits 5 and 6 are corrected versions of the corresponding Exhibits
5 and 6 that were originally filed with Defendant's Motion for Summary Judgment
and should be substituted for them. Amended Exhibit 5 contains the names and
other information about sixteen individuals who were inadvertently omitted from
the original Exhibit 5 filed with Defendant's Motion for Summary Judgment. See
February 4, 2002 Supplemental Declaration of James S. Reynolds at 8. Amended
Exhibit 6 contains hand-written corrections to mistakes or omissions that were
due to clerical error in the original Exhibit 6. See amended Exhibit 6, at pages
1, 3, 15, 17, 25, 27, 46, 55, and 56 of 58; and pages 9, 11, 18, 25, and 54
of 60. Amended Exhibit 6 also omits duplicate pages which were inadvertently
included in the original Exhibit 6.
Exhibits 7 and 8, referenced in the January 11, 2002 Declaration of James S.
Reynolds, were inadvertently omitted from defendant's original set of Exhibits.
Exhibit 7 contains the information that the Department of Justice released to
the public concerning the INS detainees prior to the filing of this lawsuit.
See Reynolds Dec. 7. Similarly, Exhibit 8 contains the information that the
Department of Justice released to the public prior to the filing of this lawsuit
concerning the persons held on federal criminal charges. See Reynolds Dec. 8.
Exhibits 9 through 11 are the slip opinions cited in the Memorandum in Support
of Defendant's Motion for Summary Judgment and are provided for the Court's
convenience. Those slip opinions include the following three cases: Dickie v.
Department of the Treasury, No. 86-649 (D.D.C. Mar. 31, 1987); Isley v. Executive
Office for United States Attorneys, No. 96-0123 (D.D.C. Mar. 27, 1997); and
Russell v. Barr, No. 92-2546 (D.D.C. Aug. 28, 1998). A fourth slip opinion cited
in defendant's Memorandum, Judicial Watch, Inc. v. United States Department
of Justice, No. 97-2869 (D.D.C. Feb. 22, 2000), is not attached because that
case is now reported at 102 F. Supp. 2d 6 (D.D.C. 2000).
Respectfully submitted,
ROBERT D. McCALLUM, JR.
Assistant Attorney General
ROSCOE C. HOWARD
United States Attorney
DAVID J. ANDERSON
ANNE L. WEISMANN
LISA A. OLSON
CAROL FEDERIGHI
U.S. Department of Justice
Civil Division, Room 1052
901 E Street, N.W.
Washington, D.C. 20530
Telephone: (202) 514-5633
Facsimile: (202) 616-8470
E-mail:
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Dated: Feb. 5, 2002 Counsel for Defendant
CERTIFICATE OF SERVICE
I hereby certify that on February 5, 2002, copies of Defendant's Notice of
Filing of Amended and Supplemental Exhibits, with attached Exhibits 5-11, were
served by hand-delivery, first-class mail, or federal express, upon plaintiffs'
counsel as follows:
David L. Sobel, Esq.
Electronic Privacy Information Center
1718 Connecticut Avenue, N.W.
Suite 200
Washington, D.C. 20009
fax: (202) 483-1248
Arthur B. Spitzer, Esq.
American Civil Liberties Union
of the National Capital Area
1400 20th Street, N.W. #119
Washington, D.C. 20036
fax: (202) 452-1868
Kate Martin, Esq.
Center for National Security Studies
2130 H Street, N.W. S. 701
Washington, D.C. 20037
fax: (202) 994-7005
Steven R. Shapiro, Esq.
Lucan Guttentag, Esq.
American Civil Liberties Union Foundation
125 Broad Street
New York, N.Y. 10004
fax: (212) 549-2651
Elliot M. Mincberg, Esq.
People for the American Way Foundation
2000 M Street, N.W., Suite 400
Washington, D.C. 20036
fax: (202) 293-2672
__________________________
LISA A. OLSON
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