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Case 1:07-cv-02338-UNA Document 34 Filed 07/22/2008 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

IN RE GUANTANAMO BAY DETAINEE
LITIGATION

MISC. ACTION NO. 08-442 (TFH)

ABDURRAHMAN ABDALLAH ALI
MAHMOUD AL SHUBATI

v.

Petitioner/Plaintiff,

GEORGE W. BUSH, et al.,

Respondents/Defendants.

CIVIL ACTION NO. 07-CV-02338
(HHK)

MEMORANDUM OF UNDERSTANDING REGARDING ACCESS TO

CLASSIFIED NATIONAL SECURITY INFORMATION

Having familiarized myself with the applicable statutes, regulations, and orders related to,

but not limited to, unauthorized disclosure of classified information, espionage and related

offenses; The Intelligence Identities Protection Act, 50 U.S.C. § 421; 18 U.S.C. § 641; 50 U.S.C.

§ 783; 28 C.F.R. § 17 et seq. and Executive Order 12958; I understand that I may be the recipient

of information and documents that belong to the United States and concern the present and future

security of the United States, and that such documents and information together with the

methods and sources of collecting it are classified by the United States government. In

consideration for the disclosure of classified information and documents:

(1) I agree that I shall never divulge, publish, or reveal either by word, conduct or any

other means, such classified documents and information unless specifically authorized in writing

to do so by an authorized representative of the United States government, or as expressly

Case 1:07-cv-02338-UNA Document 34 Filed 07/22/2008 Page 2 of 3

authorized by the Protective Order entered in the United States District Court for the District of

Columbia in the case captioned Shubati et al. v. Bush et al., Civ. Action No. 07-2337 (HHK).

(2) I agree that this Memorandum of Understanding and any other non-disclosure

agreement signed by me will remain forever binding on me.

(3) I have received, read, and understand the Protective Order entered by the United

States District Court for the District of Columbia in the case Shubati et al. v. Bush et al., Civ.

Action No. 07-2338 (HHK), and I agree to comply with the provisions thereof.

/s/ Kit A. Pierson
Kit A. Pierson



7/22/2008

Date







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Case 1:07-cv-02338-UNA Document 34 Filed 07/22/2008 Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that, on this 22nd day of July, 2008, I caused a true and correct

copy of the attached MEMORANDUM OF UNDERSTANDING REGARDING ACCESS

TO CLASSIFIED NATIONAL SECURITY INFORMATION to be served by the ECF

system on:

TERRY M. HENRY
ANDREW WARDEN
JUDRY SUBAR
United States Department of Justice
Civil Division, Federal Programs Branch
20 Massachusetts Ave., N.W.
Washington, DC 20530
Tel: (202) 514-4107
Fax: (202) 616-8470
Counsel for Respondents

/s/ Kit A. Pierson





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