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Case 1:04-cv-01254-RCL Document 793 Filed 03/26/10 Page 1 of 3



IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

Civil Action No.: 04-1254 (HHK)













Petitioners,

v.






MAHMOAD ABDAH, et al.,










BARACK H. OBAMA, et al.,






















Respondents.





















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JOINT PROPOSED SCHEDULING ORDER

Counsel for Petitioner Salman Yahya Hassan Mohammed Rabeii (ISN 508) and Counsel

for Respondents together respectfully submit this joint proposed scheduling order as noted in

Petitioner’s motion to lift the stay of his case. (Doc. 787 at 2.)

1. Unclassified Factual Return.

The Government shall file an unclassified version of the factual return for Petitioner

Salman on or before May 24, 2010.

2. Exculpatory Evidence and Required Discovery.

The Government shall comply with the requirements of Sections I.D.1 and I.E.1 of the

Case Management Order as amended (the “CMO”) on or before May 24, 2010, except with

respect to searching, and producing responsive material found among, the documents and

information provided to the Guantanamo Review Task Force (“GRTF”) as required by the

Court’s Orders of April 8, 2009 (Doc. 477) and June 18, 2009 (Doc. 530). The parties will

attempt in good faith to reach agreement regarding searches and production of this material.



Case 1:04-cv-01254-RCL Document 793 Filed 03/26/10 Page 2 of 3



3. Additional Discovery.

If Petitioner Salman seeks discovery beyond the discovery required by the CMO, he shall

file his motion to compel additional discovery no later than 28 days after the Government

completes production of all discovery (including Task Force discovery) required under Sections

I.D.1 and I.E.1 of the CMO.

4. Petitioner’s Traverse.

Petitioner Salman shall file his traverse no later than 28 days after all discovery has been

completed.

5. Merits Schedule.

The parties shall appear before the Court for a scheduling conference to set a date for a

merits hearing and a briefing schedule as soon as practicable after Petitioner’s traverse is filed.



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Case 1:04-cv-01254-RCL Document 793 Filed 03/26/10 Page 3 of 3



March 26, 2010









Respectfully submitted,

TONY WEST
Assistant Attorney General

JOSEPH HUNT
Branch Director



TERRY M. HENRY
JAMES J. GILLIGAN
Assistant Branch Directors

/s/ Mark A. Vetter
Stephen M. Elliott
Mark A. Vetter
Attorneys
United States Department of Justice
Civil Division, Federal Programs Branch
20 Massachusetts Ave., N.W.
Washington, DC 20530
Tel: (202) 305-9910

Counsel for Respondents


/s/ Brian E. Foster

S. William Livingston
D.C. Bar No. 59055
Alan A. Pemberton

D.C. Bar No. 367108
Brian E. Foster
D.C. Bar No. 988311
COVINGTON & BURLING LLP
1201 Pennsylvania Ave., N.W.
Washington, DC 20004-2401
Tel: (202) 662-6000
Fax: (202) 778-6000
[email protected]
[email protected]
[email protected]



David H. Remes

D.C. Bar. No. 370372
APPEAL FOR JUSTICE
1106 Noyes Drive
Silver Spring, MD 20910
Tel: (202) 669-6508
[email protected]

Marc D. Falkoff
D.C. Bar No. 491149
NORTHERN ILLINOIS UNIVERSITY
COLLEGE OF LAW
DeKalb, IL 60115
Tel: (347) 564-5043
Fax: (815) 753-9301
[email protected]

Counsel for Petitioner





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