October 7, 2003 Via…

                                             October 7, 2003

Via Facsimile & U.S. Mail

Re: Request Submitted Under the Freedom of Information Act

Dear Freedom of Information Officer:

        This letter constitutes a request ("Request") pursuant to the Freedom
of Information Act, 5 U.S.C. § 552 (FOIA). The Request is submitted on
behalf of the following organizations (collectively, "Requesters"):

               American Civil Liberties Union (ACLU);
               Center for Constitutional Rights (CCR);
               Physicians for Human Rights (PHR);
               Veterans for Common Sense (VCS); and
               Veterans for Peace (VFP).

        We are filing the Request simultaneously with the Department of
Defense (including its components, the Departments of the Army, Navy, and
Air Force, and the Defense Intelligence Agency), the Department of Justice
(including its components, the Federal Bureau of Investigation and Office of
Intelligence Policy and Review), the Department of State, and the Central
Intelligence Agency. In separate letters, we have applied for expedited
processing pursuant to 5 U.S.C. § 552(a)(4)(E).

                            Records Requested

        Recent news reports indicate that individuals apprehended after
September 11, 2001, and held by the United States at military bases or
detention facilities outside the United States ("Detainees") have in some
cases been tortured or subjected to interrogation techniques that are
prohibited by international and United States law. News reports also
indicate that the United States has rendered1 Detainees and other individuals
to foreign powers known to employ torture and illegal interrogation


       1
         In this Request, "rendition" means the transfer of a person by the
United States to a "foreign power," as defined in 50 U.S.C. § 1801, without
prior review by an immigration or Article III judge.
techniques. The Request seeks records relating to the treatment of Detainees
and the rendition of Detainees and other individuals.

        Both international and United States law unequivocally prohibit the
use of torture. The Convention Against Torture ("CAT"), which the United
States has signed and ratified, prohibits the use of torture and the infliction
of other cruel, inhuman or degrading treatment or punishment.2 The
prohibition against torture is also codified in United States law at 18 U.S.C.
§ 2340A.

         The CAT further provides that "[n]o State Party shall expel, return
(`refouler') or extradite a person to another State whether there are
substantial grounds for believing that he would be in danger of being
subjected to torture."3 This provision is implemented in United States law
by the Foreign Affairs Reform and Restructuring Act of 1998, which states
that "[i]t shall be the policy of the United States not to expel, extradite, or
otherwise effect the involuntary return of any person to a country in which

       2
         In this Request, the terms "torture" and "cruel, inhuman or
degrading treatment or punishment" have the meaning accorded them in the
CAT, as interpreted by the United Nations Committee Against Torture.
Convention Against Torture and Other Cruel, Inhuman or Degrading
Treatment or Punishment, Dec. 10, 1984, art. 1, S. Treaty Doc. No. 100-20
(1998), 1465 U.N.T.S. 85. The CAT defines "torture" as "any act by which
severe pain or suffering, whether physical or mental, is intentionally inflicted
on a person for such purposes as obtaining from him or a third person
information or a confession, punishing him for an act he or a third person
has committed or is suspected of having committed, or intimidating or
coercing him or a third person, or for any reason based on discrimination of
any kind, when such pain or suffering is inflicted by or at the instigation of
or with the consent or acquiescence of a public official or other person
acting in an official capacity." Id. The United Nations Committee Against
Torture has held that the following techniques constitute "torture" as defined
under the CAT: (1) restraining in very painful conditions, (2) hooding under
special conditions, (3) sounding of loud music for prolonged periods, (4)
sleep deprivation for prolonged periods, (5) threats, including death threats,
(6) violent shaking, and (7) using cold air to chill. See Report of the
Committee Against Torture, U.N. GAOR, 52d Sess., Supp. No. 44, at para
257, U.N. Doc. A/52/44 (1997). Our use of these terms also encompasses
torture and/or "cruel inhuman or degrading treatment or punishment" under
any other United States constitutional or statutory provision.
       3
           CAT, art. 3.

                                       2
there are substantial grounds for believing the person would be in danger of
being subjected to torture, regardless of whether the person is physically
present in the United States."4

        After the release of news reports indicating abuse of Detainees, the
President assured the public that "[t]he United States is committed to the
world-wide elimination of torture and we are leading this fight by
example."5 William J. Haynes, General Counsel for the Department of
Defense, has confirmed that "it is the policy of the United States to comply
with all of its legal obligations in its treatment of detainees," including its
obligations under the CAT.6 Mr. Haynes has also asserted that "[i]f the war
on terrorists of global reach requires transfer of detained enemy combatants
to other countries for continued detention on our behalf, U.S. Government
instructions are to seek and obtain appropriate assurances that such enemy
combatants are not tortured."7

        These assurances, while welcome, have failed to address the
numerous credible reports recounting the torture and rendition of Detainees.
Nor have they explained what measures, if any, the United States has taken
to ensure compliance with its legal obligations with respect to the use of
torture and the infliction of cruel, inhuman or degrading treatment or
punishment.

       To determine whether the United States is honoring its obligations
under domestic and international law, Requesters seek the release of agency
records as described in the numbered paragraphs below:


       4
         Pub. L. No. 105-277, § 2242(b), 112 Stat. 2681 (1999) (codified as
Note to 8 U.S.C. § 1231).
       5
         Statement by the President, United Nations International Day in
Support of Victims of Torture, (June 26, 2003), at
http://www.whitehouse.gov/news/releases/2003/06/20030626-3.html
       6
         Letter from William J. Haynes II, General Counsel of the
Department of Defense, to the Honorable Patrick J. Leahy, United States
Senator (June 25, 2003), at http://www.hrw.org/press/2003/06/
tortureday.htm.
       7
        Letter from William J. Haynes II, General Counsel of the
Department of Defense, to Kenneth Roth, Executive Director, Human Rights
Watch (April 2, 2003), at http://www.hrw.org/press/2003/04/
dodltr040203.pdf

                                       3
  I. Records concerning the treatment of Detainees in United States
     custody

       Discussing the treatment of individuals detained by the United States
at Bagram Airbase in Afghanistan, a December 2002 article from the
Washington Post reports:

       Those [detainees] who refuse to cooperate inside this secret
       CIA interrogation center are sometimes kept standing or
       kneeling for hours, in black hoods or spray-painted goggles,
       according to intelligence specialists familiar with CIA
       interrogation methods. At times they are held in awkward,
       painful positions and deprived of sleep with a 24-hour
       bombardment of lights ­ subject to what are known as "stress
       and duress" techniques. . . .

       According to Americans with direct knowledge and others
       who have witnessed the treatment, captives are often
       "softened up" by MPs and U.S. Army Special Forces troops
       who beat them up and confine them in tiny rooms. The
       alleged terrorists are commonly blindfolded and thrown into
       walls, bound in painful positions, subject to loud noises and
       deprived of sleep.

Dana Priest & Barton Gellman, U.S. Decries Abuse but Defends
Interrogations, Washington Post, Dec. 26, 2002, at A01. A March 2003
article from The New York Times reports:

       Two former prisoners [at Bagram], Abdul Jabar and Hakkim
       Shah . . . said the conditions to which they themselves were
       subjected at the time included standing naked, hooded and
       shackled, being kept immobile for long periods and being
       deprived of sleep for days on end.

       Such accounts appear to raise troubling questions about the
       conditions of detention and the interrogation of prisoners in
       the fight against terror . . . .

       Mr. Jabar and Mr. Shah said they had been made to stand
       hooded, their arms raised and chained to the ceiling, their feet
       shackled, unable to move for hours at a time, day and night.



                                      4
       Mr. Jabar said he endured this treatment for 13 days. The
       prisoners, he said, were freed from their standing position
       only to eat, pray and go to the bathroom.

       Mr. Shah said he had spent 16 days in the upstairs rooms,
       standing for 10 of them until his legs became so swollen that
       the shackles around his ankles tightened and stopped the
       blood flow.

       He said he was naked the entire time and allowed to dress
       only when he was taken for interrogation or to the bathroom.
       Mr. Shah said the cold kept him awake, as did the American
       guards, who kicked and shouted at him to stop him falling
       asleep.

       None of four former prisoners interviewed said they had been
       beaten. But some said they had been kicked by their guards
       and interrogators, either to prevent them from sleeping or
       during their interrogations.

Carlotta Gall, Death of an Afghan in Custody, N.Y. Times, Mar. 4, 2003, at
A14.

        The Washington Post article cited above suggests that the
maltreatment of detainees may be accepted and even encouraged by senior
officials:

       "If you don't violate someone's human rights some of the
       time, you probably aren't doing your job," said one official
       who has supervised the capture and transfer of accused
       terrorists. "I don't think we want to be promoting a view of
       zero tolerance on this. That was the whole problem for a long
       time with the CIA." . . . .

       At a Sept. 26 joint hearing of the House and Senate
       intelligence committees, Cofer Black, then head of the CIA
       Counterterrorist Center, spoke cryptically about the agency's
       new forms of "operational flexibility" in dealing with
       suspected terrorists. "This is a very highly classified area, but
       I have to say that all you need to know: There was a before
       9/11, and there was an after 9/11," Black said. "After 9/11
       the gloves come off."


                                      5
Priest & Gellman, supra.

       Please disclose the following records:

     1.    All records setting forth or discussing the legality or
           appropriateness of subjecting Detainees to torture or other cruel,
           inhuman or degrading treatment or punishment. Please include
           all records discussing the legality or appropriateness of the
           following methods: using "stress and duress" techniques on
           Detainees; using force against them; subjecting them to physical
           injury; requiring them to stand or kneel for prolonged periods;
           depriving them of sleep, food or water; holding them in awkward
           and painful positions for prolonged periods; denying them
           painkillers or medical treatment; administering or threatening to
           administer mind altering substances, "truth serums" or
           procedures calculated to disrupt the senses or personality;
           subjecting them to prolonged interrogation under bright lights;
           requiring them to be hooded, stripped, or blindfolded; binding
           their hands and feet for prolonged periods of time; isolating them
           for prolonged periods of time; subjecting them to violent shaking;
           subjecting them to intense noise; using cold air to chill them; or
           threatening harm to them or other individuals.

     2.    All records setting forth or discussing policies, procedures or
           guidelines8 relating to the torture or other cruel, inhuman or
           degrading treatment or punishment of Detainees, including but
           not limited to policies, procedures or guidelines relating to the
           methods listed in Paragraph 1, above.

     3.    All records relating to measures taken, or policies, procedures or
           guidelines put in place, to ensure that Detainees were not, are not
           or will not be tortured or subjected to cruel, inhuman or
           degrading treatment or punishment. Please include all records
           indicating how any such policies, procedures or guidelines were,
           are or will be communicated to personnel involved in the
           interrogation or detention of Detainees.




       8
         In this Request, the phrase "policies, procedures or guidelines"
means policies, procedures or guidelines that were in force on September 11,
2001 or that have been put in place since that date.

                                      6
4.    All records indicating or discussing actual or possible violations
      of, or deviations from, the policies, procedures or guidelines
      referred to in Paragraph 2, above.

5.    All records relating to investigations, inquiries, or disciplinary
      proceedings initiated in relation to actual or possible violations
      of, or deviations from, the policies, procedures or guidelines
      referred to in Paragraph 2, above, including but not limited to
      records indicating the existence of such investigations, inquiries
      or disciplinary proceedings.

6.    All records relating to the actual or alleged torture or other cruel,
      inhuman or degrading treatment or punishment of any Detainee.

7.    All records relating to policies, procedures or guidelines
      governing the role of health personnel in the interrogation of
      Detainees, including but not limited to the role of health
      personnel in the medical, psychiatric, or psychological
      assessment of Detainees immediately before, during or
      immediately after interrogation. Please include all records
      indicating how any such policies, procedures or guidelines were,
      are or will be communicated to personnel involved in the
      interrogation or detention of Detainees.

8.    All records relating to medical, psychiatric or psychological
      assessment of any Detainee or guidance given to interrogators by
      health personnel immediately before, during or immediately after
      the interrogation of any Detainee.

9.    All records indicating whether and to what extent the
      International Committee for the Red Cross ("ICRC") had, has or
      will have access to Detainees, including but not limited to records
      related to particular decisions to grant or deny the ICRC access to
      any Detainee or group of Detainees.

10.   All records indicating whether and to what extent any other non-
      governmental organization or foreign government had, has or
      will have access to Detainees, including but not limited to records
      related to particular decisions to grant or deny them access to any
      Detainee or group of Detainees.




                                  7
 II. Records concerning the death of Detainees in United States
     custody

        News reports indicate that a number of Detainees have died while
held at Bagram Air Base in Afghanistan. A March 2003 article from The
New York Times reports:

       The United States military has begun a criminal investigation
       into the death of an Afghan man in American custody in
       December, a death described as a "homicide" by an American
       pathologist.

       A death certificate, dated Dec. 13 and signed by Maj.
       Elizabeth A. Rouse, a pathologist with the Armed Forces
       Institute of Pathology, based in Washington, says the man
       died as a result of "blunt force injuries to lower extremities
       complicating coronary artery disease."

       The Afghan, known by the single name Dilawar, a 22-year-
       old farmer and part-time taxi driver from this village in
       eastern Afghanistan, died in December while being held in
       the main United States air base at Bagram, north of Kabul. . .
       .

       Chris Kelly, public affairs director at the Armed Forces
       Institute of Pathology, speaking from Washington, said Major
       Rouse had taken part in the autopsies of two Afghan men
       who died in custody at Bagram last year, one of whom was
       Mr. Dilawar. . . .

       [Another] Afghan man also died in American custody on
       Dec. 3. He was Mullah Habibullah, brother of a former
       Taliban commander. He was about 30, from the southern
       province of Oruzgan, and was held in the same detention
       center at Bagram.

       His family said no American official had given them any
       information or explanation about the death, which was
       learned from the International Committee of the Red Cross.

Gall, supra; see also Barbara Starr, Afghan detainees' deaths ruled
homicides, CNN.com, Mar. 5, 2003 (noting that the "criminal investigation"
into the deaths of two Afghan detainees was in its final stages, and relating

                                       8
the acknowledgement of one senior military official that "[t]his investigation
may not go well for us."); April Witt, U.S. Probes Death of Prisoner in
Afghanistan, Washington Post, June 24, 2003, at A18 (reporting the death of
an Afghan man held at a United States holding facility near Asadabad, in the
eastern province of Konar, Afghanistan).

   Please disclose:

     11.   All records, including autopsy reports and death certificates,
           relating to any deaths of Detainees.

     12.   All records relating to investigations, inquiries, or disciplinary
           proceedings initiated as a result of any deaths of Detainees,
           including but not limited to records indicating the existence of
           such investigations, inquiries, or disciplinary proceedings.


III. Records related to the rendition of Detainees and other individuals

       News reports indicate that individuals have been rendered to foreign
powers known to employ torture or illegal interrogation techniques. One
news report states:

       In other cases, usually involving lower-level captives, the
       CIA hands them to foreign intelligence services ­ notable
       those of Jordan, Egypt, and Morocco ­ with a list of questions
       the agency wants answered. These "extraordinary renditions"
       are done without resort to legal process and usually involve
       countries with security services known for using brutal
       means. . . .

       According to one official who has been directly involved in
       rendering captives into foreign hands, the understanding is,
       "We don't kick the [expletive] out of them. We send them to
       other countries so they can kick the [expletive] out of them."

Priest & Gellman, supra; see also David E. Kaplan, Aamir Latif, Ilana
Ozernoy, Laurie Lande, Monica M. Ekman, Playing Offense: The inside
story of how U.S. terrorist hunters are going after al Qaeda, U.S. News &
World Report, June 2, 2003 ("The CIA has helped move dozens of detainees
not only to Jordan but also to Egypt, Morocco, and even Syria.").
Statements of senior officials suggest that the United States may be
complicit in the torture of rendered individuals:

                                       9
       The CIA's participation in the interrogation of rendered
       terrorist suspects varies from country to country.

       "In some cases [involving interrogations in Saudi Arabia],
       we're able to observe through one-way mirrors the live
       investigations," said a senior U.S official involved in Middle
       East security issues. "In others, we usually get summaries.
       We will feed questions to their investigators. They're still
       very much in control."

Id. Another news report quotes Vince Cannistraro, former director of the
CIA's counterterrorism center, on the treatment of a Guantanamo Bay
Detainee who was sent to Egypt for "failing to cooperate": "They promptly
tore his fingernails out and he started telling things." Tom Brune, An
Aggressive Interrogation, Newsday, Mar. 4, 2003, at A05.

       We are interested in obtaining records indicating the circumstances
under which the United States has rendered Detainees or other individuals to
foreign powers that are known or suspected to use torture or to inflict cruel,
inhuman or degrading treatment or punishment.

       Please disclose:

     13.   All records setting forth or discussing the legality or
           appropriateness of the rendition of individuals who may be
           tortured or subjected to cruel, inhuman or degrading treatment or
           punishment after their rendition.

     14.   All records setting forth or discussing policies, procedures or
           guidelines relating to the rendition of individuals who may be
           tortured or subjected to cruel, inhuman or degrading treatment or
           punishment after their rendition.

     15.   All records relating to measures taken, or policies, procedures or
           guidelines put in place, to ensure that rendered individuals were
           not, are not, or will not be tortured or subjected to cruel, inhuman
           or degrading treatment or punishment after their rendition.
           Please include all records indicating how any such policies,
           procedures or guidelines were, are or will be communicated to
           personnel involved in the interrogation, detention or rendition of
           individuals.


                                      10
      16.   All records relating to actual or possible violations of, or
            deviations from the policies, procedures or guidelines referred to
            in Paragraph 14, above.

      17.   All records relating to the involvement of United States personnel
            in the interrogation of individuals after they have been rendered.

      18.   All records relating to investigations, inquiries or disciplinary
            proceedings initiated in relation to actual or possible violations
            of, or deviations from, the policies, procedures or guidelines
            referred to in Paragraph 14, above, including but not limited to
            records indicating the existence of such investigations, inquiries
            or disciplinary proceedings.

      19.   All records relating to the actual or alleged torture or cruel,
            inhuman or degrading treatment or punishment of any Detainee
            after his rendition.

      20.   All records related to assurances sought or obtained from foreign
            powers to whom individuals have been rendered regarding the
            treatment of those individuals.

      21.   All records indicating whether and to what extent the ICRC or
            other non-governmental organizations had, have, or will have
            access to individuals after they have been rendered.


                                   Fee Waiver

        The ACLU, CCR, PHR and VFP qualify as "representatives of the
news media" and the records are not sought for commercial use.
Accordingly, fees associated with the processing of the Request should be
"limited to reasonable standard charges for document duplication." 5 U.S.C.
§ 552(a)(4)(A)(ii)(II). These organizations are "entit[ies] that gather . . .
information of potential interest to a segment of the public, use . . . [their]
editorial skills to turn the raw materials into a distinct work, and distribute . .
. that work to an audience." National Security Archive v. Department of
Defense, 880 F.2d 1381, 1387 (D.C. Cir. 1989).

        The ACLU is a nationwide, not-for-profit, non-partisan organization
with over 400,000 members dedicated to the principles of liberty and
equality. It has long believed that our nation's commitment to civil liberties


                                        11
values is enhanced by adherence to appropriate international human rights
norms, including the prohibition against torture.

        The ACLU publishes newsletters, news briefings, right-to-know
handbooks, and other materials that are disseminated to the public. These
materials are widely available to everyone, including tax-exempt
organizations, not-for-profit groups, law students and faculty, for no cost or
for a nominal fee through its public education department. The ACLU also
disseminates information through its heavily subscribed website,
www.aclu.org. The website addresses civil liberties issues in depth,
provides features on civil liberties issues in the news, and contains hundreds
of documents that relate to the issues addressed by the ACLU. The website
includes features on information obtained through the FOIA. See, e.g.,
www.aclu.org/patriot_foia. The ACLU also publishes an electronic
newsletter, which is distributed to subscribers by e-mail. On account of
these factors, the ACLU has not been charged fees associated with
responding to FOIA requests on numerous occasions.9

        CCR is a legal and public education not-for-profit organization that
engages in litigation, legal research, and the production of publications in the
fields of civil and international human rights. CCR also publishes
newsletters, know-your-rights handbooks, and other similar materials for
public dissemination. These materials are available through CCR's
Development and Education & Outreach Departments. CCR also operates a
website, www.ccr-ny.org, that addresses the issues on which the Center
works. The website includes material on topical civil and human rights
issues and material concerning CCR's work. All of this material is freely
available to the public.


       9
          The following are recent examples of requests in which agencies
did not charge the ACLU fees associated with responding to a FOIA request:
(1) The Office of Science and Technology Policy in the Executive Office of
the President has told the ACLU that it will waive the fees associated with a
FOIA request submitted by the ACLU in August 2003; (2) The Federal
Bureau of Investigation did not charge the ACLU fees associated with a
FOIA request submitted by the ACLU in August 2002; (3) The Office of
Intelligence Policy and Review did not charge the ACLU fees associated
with a FOIA request submitted by the ACLU in August 2002; and (4) The
Office of Information and Privacy in the Department of Justice did not
charge the ACLU fees associated with a FOIA request submitted by the
ACLU in August 2002.

                                      12
        PHR is a not-for-profit organization whose mission is to promote
health by protecting human rights. It uses scientific methods and clinical
medical skills to investigate allegations of human rights violations. PHR has
conducted medical investigations of torture throughout the world and played
a lead role in developing the principal international instrument for the
medical evaluation of torture, the Istanbul Protocol. PHR publishes
newsletters, reports, and informational materials for the public, many of
which are available on its website, www.phrusa.org. The website contains a
section on torture and the means for preventing it. PHR also distributes an
email newsletter free of charge to the public.

         VCS, a Washington D.C. based, non-profit, United States veterans'
organization, is committed to providing a voice of reason on issues of war
and national security from the unique perspective of those who have served
their country in uniform. VCS stands firm on the principal that our nation's
precious youth should only be committed to battle under the gravest of
circumstances and therefore seek to return our country to a time when war is
truly the policy of last resort. To this purpose, it informs fellow citizens of
the terrible costs of war, by challenging policies that abuse the trust of
military service members and by speaking out in defense of the values
espoused in the oath its members take to support and defend the Constitution
of the United States. VCS disseminates information through its website,
www.veteransforpeace.org, news briefings, media interviews, published
editorials and direct contact through email to the general membership.

        VFP is a not-for-profit, non-partisan organization of United States
war veterans who served from World War II through Gulf War I. There are
85 VFP chapters across the nation, from Alaska to Florida. VFP consists of
men and women who, having dutifully served their nation, now embrace a
greater responsibility to serve the cause of world peace. To this end they
work with others to: (1) increase public awareness of the costs of war; (2)
restrain the United States government from intervening, overtly and
covertly, in the internal affairs of other nations; (3) end the arms race and
reduce and eventually eliminate nuclear weapons; (4) seek justice for
veterans and victims of war, and (5) abolish war as an instrument of national
policy. VFP disseminates information through its website,
www.veteransforpeace.org, listserves to the general on-line membership,
chapter contacts, and a quarterly newsletter.

       The records requested are not sought for commercial use, and the
requesters plan to disseminate the information disclosed as a result of this
FOIA request through the channels described above.


                                      13
        We also request a waiver of fees on the grounds that disclosure of the
requested records is in the public interest and because disclosure "is likely to
contribute significantly to the public understanding of the activities or
operations of the government and is not primarily in the commercial interest
of the requester[s]." 5 U.S.C. § 552(a)(4)(A)(iii). This Request aims at
furthering public understanding of government conduct, and specifically to
help the public determine whether or not the government's commitment to
domestic and international proscriptions against torture is honored in
practice.

        As indicated above, numerous news articles reflect the significant
public interest in the records we seek. See articles cited supra; see also
Answers about Torture, Washington Post, Mar. 16, 2003, at B06 ("The Bush
administration has categorically denied that it is torturing people. But it has
offered no details regarding its policies toward interrogations. . . . The
secrecy surrounding U.S. policy makes any objective assessment of these
allegations impossible. . . . The public is entitled to a fuller understanding.").
Disclosure of the requested records will contribute significantly to the
public's understanding of government conduct.


                                *       *       *

        If our request is denied in whole or part, we ask that you justify all
deletions by reference to specific exemptions of the FOIA. We expect you
to release all segregable portions of otherwise exempt material. We reserve
the right to appeal a decision to withhold any information or to deny a
waiver of fees.

       As indicated above, we are applying in a separate letter for expedited
processing of this Request. Notwithstanding your determination of that
application, we look forward to your reply to the Request within twenty (20)
business days, as required under 5 U.S.C. § 552(a)(6)(A)(i).

        Thank you for your prompt attention to this matter.




                                       14
        Please respond to Amrit Singh, Staff Attorney, American Civil
Liberties Union, 125 Broad Street, 18th Floor, New York, NY 10004,
telephone (212) 549-2609.


                                            Signed by:


                                            _______________________
STEVEN WATT                                 AMRIT SINGH
BARBARA OLSHANSKY                           OMAR C. JADWAT
MICHAEL RATNER                              JAMEEL JAFFER
Center for Constitutional Rights            American Civil Liberties Union
666 Broadway, 7th Floor                     125 Broad Street, 18th Floor
New York, NY 10012                          New York, NY 10004
Tel: (212) 614-6464                         Tel: (212) 549-2609
Fax: (212) 614-6499                         Fax: (212) 549-2654




                                    15