Plaintiff’s Requests for Discovery: Request for Production of Documents

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

CENTER FOR NATIONAL SECURITY STUDIES, )
et al., )
)
Plaintiffs, )
) Civil Action
v. ) No. 01-2500
)
DEPARTMENT OF JUSTICE, ) Judge Kessler
)
Defendant. )
______________________________________)

PLAINTIFFS’ REQUESTS FOR PRODUCTION OF DOCUMENTS

Pursuant to Fed. R. Civ. P. 34, plaintiffs hereby request defendant to produce for inspection and copying the documents specified below, at the office of plaintiff’s counsel, 1400 20th Street, N.W., Suite 119, Washington, D.C., at 10 o’clock a.m. on Monday, February 25, 2002, or at such other time as the Court may require, unless a different mutually agreeable time and place is designated by counsel.

Definitions: in these requests for documents, the term “document” includes letters, correspondence, memoranda, reports, summaries, notes, lists, publications, and any and all other writings, whether on paper, film, tape, or electronic media, and includes any written record made of any oral or electronic communication; the term “terrorism investigation” refers to the investigation that has been conducted in the wake of the September 11, 2001, attacks on the World Trade Center and the Pentagon, and the term “detainees” refers to individuals who are, or have been, detained in connection with the terrorism investigation.

Should defendant claim a privilege for any document requested, identify the document(s) withheld under such claim of privilege, indicate the nature of the claimed privilege, and state why each such document is entitled to the privilege asserted.

Please produce:

1. All non-governmental publications (newspapers, magazines, newsletters, Internet pages, and the like) identifying by name individuals who are reported or purported to be detainees or former detainees, to the extent such documents are maintained in a central file or collection.

Very truly yours,

_____________________________________
David L. Sobel
D.C. Bar No. 360418
Electronic Privacy Information Center
1718 Connecticut Avenue, N.W. #200
Washington, DC 20009
tel. 202-483-1140
fax 202-483-1248

_____________________________________
Arthur B. Spitzer
D.C. Bar. No. 235960
American Civil Liberties Union
of the National Capital Area
1400 20th Street, N.W. #119
Washington, D.C. 20036
tel. 202-457-0800
fax 202-452-1868

Kate Martin
D.C. Bar No. 949115
Center for National Security Studies
2130 H Street, N.W. #701
Washington, D.C. 20037
202-994-7060

Steven R. Shapiro
Lucas Guttentag
American Civil Liberties Union Foundation
125 Broad Street
New York, N.Y. 10004
212-549-2500

Elliot M. Mincberg
D.C. Bar No. 941575
People For the American Way Foundation
2000 M Street N.W., Suite 400
Washington, D.C. 20036
tel. 202-467-4999
fax 202-293-2672

Counsel for Plaintiffs

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Plaintiffs’ Requests for Production of Documents was served by first-class mail and by fax upon:

David J. Anderson, Esq.
Anne L. Weismann, Esq.
Lisa A. Olson, Esq.
United States Department of Justice
Civil Division, Room 1052
901 E Street, N.W.
Washington, DC 20530

fax: 202-616-8470

this 12th day of February, 2002.

________________________
Arthur B. Spitzer

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