Plaintiff’s Requests for Discovery: Requests for Admissions

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 ADMISSIONS

Pursuant to Fed. R. Civ. P. 36, plaintiffs hereby request defendant to admit, for purposes of this action, the truth of the following statements.

Please note that, pursuant to Fed. R. Civ. P. 36(a), the truth of these statements will be deemed admitted unless, within 30 days after service of this request, or within such other time as the Court may require, you have served written answers or objections upon the undersigned as provided in that rule.

These requests for admissions are continuing in nature. If defendant obtains additional information that would change an answer, a supplemental response should promptly be made.

Definitions: in these requests for admissions, 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; the term “detainees” refers to individuals who are, or have been, detained in connection with the terrorism investigation; and the term “Amended List of INS Detainees” refers to the document of that title filed as Exhibit 6 to defendant’s opposition to plaintiffs’ motion to stay proceedings in this case.

Please admit that:

1. Some individuals on the Amended List of INS Detainees have been released from custody.

2. Some individuals on the Amended List of INS Detainees have been deported.

3. Some individuals on the Amended List of INS Detainees have been granted voluntary departure by the INS in lieu of being subject to removal proceedings.

4. Some individuals on the Amended List of INS Detainees have been granted voluntary departure by an Immigration Judge.

5. Defendant maintains a central file or collection of press clippings and/or news reports and/or Internet printouts that purport to contain identifying information about detainees.

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 Admissions 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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