Table of Contents

The Center for National Security Studies
v. The Department Of JusticeThe links below 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 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
  • INS Special Interest List (page 1 of 118)
  • List of federal complaints
• Plaintiff’s Motion to Stay Proceedings on Defendant’s Summary Judgment Motion Pending Discovery and supporting documents, January 22, 2002
  • Motion to Stay Proceedings Pending Discovery
  • David L. Sobel Affidavit, Plaintiff’s Co-Counsel, CNSS et. al. v. DOJ
  • Elizabeth S. Westfall Affidavit, not available at this time
• 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
  • Preliminary Statement
  • Supplemental Affidavit of James S. Reynolds, Chief, Terrorism and Violent Crime Section, Criminal Division, DOJ
  • Defendant’s Notice of Filing Amended and Supplemental Exhibits
  • Amended INS Special Interest List (page 1 of 118)
  • Amended list of federal complaints
  • INS Detainee list publicly released prior to law suit, released November 27, 2001 and available on main Secret Arrests page
  • List of federal complaints publicly released prior to law suit, released November 27, 2001 and available on main Secret Arrests page
• 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
  • Motion to Require Expedited Responses to Discovery
  • Request for Admissions
  • Interrogatories
  • Request for Production of Documents
• Judge Kessler’s Opinion on Plaintiffs’ Motion for Discovery, February 21, 2002
• Plaintiffs’ Cross-Motion for Summary Judgment, March 18, 2002
  • Cross-Motion for Summary Judgment
  • Memorandum in Support of Cross-Motion for Summary Judgment
  • Statement of Material Facts
  • Response to Defendant’s Statement of Material Facts
  • Index of Exhibits
• 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
  • Supplemental 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
  • Index of Exhibits
• 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:
  • Supplemental Memo filed by Plaintiffs, June 14, 2002
  • Answers to Judge’s Questions filed by Defendants, June 14, 2002
• 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
  • Defendant’s Motion to Stay Decision
  • Defendant’s Memorandum in Support of Motion to Stay Decision
• 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)