CONCLUSION Consistent with the habeas statute and the substantial liberty deprivations at issue in these cases of executive detention, Petitioners are in all cases entitled to discovery and an evidentiary hearing on disputed issues of material fact in which the government must justify its detention by clear and convincing evidence. Because of the equitable and adaptable nature of the habeas remedy and the command of the habeas statute to “dispose of the case as law and justice require,” 28 U.S.C. § 2243, most of the issues related to the scope of discovery, the scope of the confrontation right and the admissibility of hearsay evidence will have to be decided by individual judges based on the facts and circumstances of the particular cases before them. Dated: July 25, 2008 Respectfully submitted, /s/ sdk Shayana D. Kadidal (D.C. Bar No. 454248) J. Wells Dixon CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012 Tel: (212) 614-6438 Case 1:05-cv-01555-UNA Document 89 Filed 07/25/2008 Page 35 of 36 36 Fax: (212) 614-6499 Baher Azmy SETON HALL LAW SCHOOL Center for Social Justice One Newark Center Newark, NJ 07102 Tel: (973) 642-8700 On Behalf of Petitioners David J. Cynamon (D.C. Bar No. 182477) Matthew J. MacLean (D.C. Bar No. 479257) PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, N.W. Washington, DC 20037 Tel: (202) 663-8000 Fax: (202) 663-8007 Attorneys for Petitioners Fawzi Khalid Abdullah

CONCLUSION Consistent with the habeas statute and the substantial liberty deprivations at issue in these cases of executive detention, Petitioners are in all cases entitled to discovery and an evidentiary hearing on disputed issues of material fact in which the government must justify its detention by clear and convincing evidence. Because of the equitable and adaptable nature of the habeas remedy and the command of the habeas statute to “dispose of the case as law and justice require,” 28 U.S.C. § 2243, most of the issues related to the scope of discovery, the scope of the confrontation right and the admissibility of hearsay evidence will have to be decided by individual judges based on the facts and circumstances of the particular cases before them. Dated: July 25, 2008 Respectfully submitted, /s/ sdk Shayana D. Kadidal (D.C. Bar No. 454248) J. Wells Dixon CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012 Tel: (212) 614-6438 Case 1:06-cv-01767-UNA Document 64 Filed 07/25/2008 Page 35 of 36 36 Fax: (212) 614-6499 Baher Azmy SETON HALL LAW SCHOOL Center for Social Justice One Newark Center Newark, NJ 07102 Tel: (973) 642-8700 On Behalf of Petitioners David J. Cynamon (D.C. Bar No. 182477) Matthew J. MacLean (D.C. Bar No. 479257) PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, N.W. Washington, DC 20037 Tel: (202) 663-8000 Fax: (202) 663-8007 Attorneys for Petitioners Fawzi Khalid Abdullah

CONCLUSION Consistent with the habeas statute and the substantial liberty deprivations at issue in these cases of executive detention, Petitioners are in all cases entitled to discovery and an evidentiary hearing on disputed issues of material fact in which the government must justify its detention by clear and convincing evidence. Because of the equitable and adaptable nature of the habeas remedy and the command of the habeas statute to “dispose of the case as law and justice require,” 28 U.S.C. § 2243, most of the issues related to the scope of discovery, the scope of the confrontation right and the admissibility of hearsay evidence will have to be decided by individual judges based on the facts and circumstances of the particular cases before them. Dated: July 25, 2008 Respectfully submitted, /s/ sdk Shayana D. Kadidal (D.C. Bar No. 454248) J. Wells Dixon CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012 Tel: (212) 614-6438 Case 1:05-cv-02349-UNA Document 58 Filed 07/25/2008 Page 35 of 36 36 Fax: (212) 614-6499 Baher Azmy SETON HALL LAW SCHOOL Center for Social Justice One Newark Center Newark, NJ 07102 Tel: (973) 642-8700 On Behalf of Petitioners David J. Cynamon (D.C. Bar No. 182477) Matthew J. MacLean (D.C. Bar No. 479257) PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, N.W. Washington, DC 20037 Tel: (202) 663-8000 Fax: (202) 663-8007 Attorneys for Petitioners Fawzi Khalid Abdullah

CONCLUSION Consistent with the habeas statute and the substantial liberty deprivations at issue in these cases of executive detention, Petitioners are in all cases entitled to discovery and an evidentiary hearing on disputed issues of material fact in which the government must justify its detention by clear and convincing evidence. Because of the equitable and adaptable nature of the habeas remedy and the command of the habeas statute to “dispose of the case as law and justice require,” 28 U.S.C. § 2243, most of the issues related to the scope of discovery, the scope of the confrontation right and the admissibility of hearsay evidence will have to be decided by individual judges based on the facts and circumstances of the particular cases before them. Dated: July 25, 2008 Respectfully submitted, /s/ sdk Shayana D. Kadidal (D.C. Bar No. 454248) J. Wells Dixon CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012 Tel: (212) 614-6438 Case 1:05-cv-01429-UNA Document 113 Filed 07/25/2008 Page 35 of 36 36 Fax: (212) 614-6499 Baher Azmy SETON HALL LAW SCHOOL Center for Social Justice One Newark Center Newark, NJ 07102 Tel: (973) 642-8700 On Behalf of Petitioners David J. Cynamon (D.C. Bar No. 182477) Matthew J. MacLean (D.C. Bar No. 479257) PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, N.W. Washington, DC 20037 Tel: (202) 663-8000 Fax: (202) 663-8007 Attorneys for Petitioners Fawzi Khalid Abdulla

CONCLUSION Consistent with the habeas statute and the substantial liberty deprivations at issue in these cases of executive detention, Petitioners are in all cases entitled to discovery and an evidentiary hearing on disputed issues of material fact in which the government must justify its detention by clear and convincing evidence. Because of the equitable and adaptable nature of the habeas remedy and the command of the habeas statute to “dispose of the case as law and justice require,” 28 U.S.C. § 2243, most of the issues related to the scope of discovery, the scope of the confrontation right and the admissibility of hearsay evidence will have to be decided by individual judges based on the facts and circumstances of the particular cases before them. Dated: July 25, 2008 Respectfully submitted, /s/ sdk Shayana D. Kadidal (D.C. Bar No. 454248) J. Wells Dixon CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012 Tel: (212) 614-6438 Case 1:05-cv-01244-UNA Document 49 Filed 07/25/2008 Page 35 of 36 36 Fax: (212) 614-6499 Baher Azmy SETON HALL LAW SCHOOL Center for Social Justice One Newark Center Newark, NJ 07102 Tel: (973) 642-8700 On Behalf of Petitioners David J. Cynamon (D.C. Bar No. 182477) Matthew J. MacLean (D.C. Bar No. 479257) PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, N.W. Washington, DC 20037 Tel: (202) 663-8000 Fax: (202) 663-8007 Attorneys for Petitioners Fawzi Khalid Abdullah

CONCLUSION Consistent with the habeas statute and the substantial liberty deprivations at issue in these cases of executive detention, Petitioners are in all cases entitled to discovery and an evidentiary hearing on disputed issues of material fact in which the government must justify its detention by clear and convincing evidence. Because of the equitable and adaptable nature of the habeas remedy and the command of the habeas statute to “dispose of the case as law and justice require,” 28 U.S.C. § 2243, most of the issues related to the scope of discovery, the scope of the confrontation right and the admissibility of hearsay evidence will have to be decided by individual judges based on the facts and circumstances of the particular cases before them. Dated: July 25, 2008 Respectfully submitted, /s/ sdk Shayana D. Kadidal (D.C. Bar No. 454248) J. Wells Dixon CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012 Tel: (212) 614-6438 Case 1:05-cv-01457-UNA Document 49 Filed 07/25/2008 Page 35 of 36 36 Fax: (212) 614-6499 Baher Azmy SETON HALL LAW SCHOOL Center for Social Justice One Newark Center Newark, NJ 07102 Tel: (973) 642-8700 On Behalf of Petitioners David J. Cynamon (D.C. Bar No. 182477) Matthew J. MacLean (D.C. Bar No. 479257) PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, N.W. Washington, DC 20037 Tel: (202) 663-8000 Fax: (202) 663-8007 Attorneys for Petitioners Fawzi Khalid Abdullah

CONCLUSION Consistent with the habeas statute and the substantial liberty deprivations at issue in these cases of executive detention, Petitioners are in all cases entitled to discovery and an evidentiary hearing on disputed issues of material fact in which the government must justify its detention by clear and convincing evidence. Because of the equitable and adaptable nature of the habeas remedy and the command of the habeas statute to “dispose of the case as law and justice require,” 28 U.S.C. § 2243, most of the issues related to the scope of discovery, the scope of the confrontation right and the admissibility of hearsay evidence will have to be decided by individual judges based on the facts and circumstances of the particular cases before them. Dated: July 25, 2008 Respectfully submitted, /s/ sdk Shayana D. Kadidal (D.C. Bar No. 454248) J. Wells Dixon CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012 Tel: (212) 614-6438 Case 1:05-cv-01639-UNA Document 50 Filed 07/25/2008 Page 35 of 36 36 Fax: (212) 614-6499 Baher Azmy SETON HALL LAW SCHOOL Center for Social Justice One Newark Center Newark, NJ 07102 Tel: (973) 642-8700 On Behalf of Petitioners David J. Cynamon (D.C. Bar No. 182477) Matthew J. MacLean (D.C. Bar No. 479257) PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, N.W. Washington, DC 20037 Tel: (202) 663-8000 Fax: (202) 663-8007 Attorneys for Petitioners Fawzi Khalid Abdullah

CONCLUSION Consistent with the habeas statute and the substantial liberty deprivations at issue in these cases of executive detention, Petitioners are in all cases entitled to discovery and an evidentiary hearing on disputed issues of material fact in which the government must justify its detention by clear and convincing evidence. Because of the equitable and adaptable nature of the habeas remedy and the command of the habeas statute to “dispose of the case as law and justice require,” 28 U.S.C. § 2243, most of the issues related to the scope of discovery, the scope of the confrontation right and the admissibility of hearsay evidence will have to be decided by individual judges based on the facts and circumstances of the particular cases before them. Dated: July 25, 2008 Respectfully submitted, /s/ sdk Shayana D. Kadidal (D.C. Bar No. 454248) J. Wells Dixon CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012 Tel: (212) 614-6438 Case 1:08-cv-01207-UNA Document 8 Filed 07/25/2008 Page 35 of 36 36 Fax: (212) 614-6499 Baher Azmy SETON HALL LAW SCHOOL Center for Social Justice One Newark Center Newark, NJ 07102 Tel: (973) 642-8700 On Behalf of Petitioners David J. Cynamon (D.C. Bar No. 182477) Matthew J. MacLean (D.C. Bar No. 479257) PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, N.W. Washington, DC 20037 Tel: (202) 663-8000 Fax: (202) 663-8007 Attorneys for Petitioners Fawzi Khalid Abdullah

CONCLUSION Consistent with the habeas statute and the substantial liberty deprivations at issue in these cases of executive detention, Petitioners are in all cases entitled to discovery and an evidentiary hearing on disputed issues of material fact in which the government must justify its detention by clear and convincing evidence. Because of the equitable and adaptable nature of the habeas remedy and the command of the habeas statute to “dispose of the case as law and justice require,” 28 U.S.C. § 2243, most of the issues related to the scope of discovery, the scope of the confrontation right and the admissibility of hearsay evidence will have to be decided by individual judges based on the facts and circumstances of the particular cases before them. Dated: July 25, 2008 Respectfully submitted, /s/ sdk Shayana D. Kadidal (D.C. Bar No. 454248) J. Wells Dixon CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012 Tel: (212) 614-6438 Case 1:06-cv-01766-UNA Document 45 Filed 07/25/2008 Page 35 of 36 36 Fax: (212) 614-6499 Baher Azmy SETON HALL LAW SCHOOL Center for Social Justice One Newark Center Newark, NJ 07102 Tel: (973) 642-8700 On Behalf of Petitioners David J. Cynamon (D.C. Bar No. 182477) Matthew J. MacLean (D.C. Bar No. 479257) PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, N.W. Washington, DC 20037 Tel: (202) 663-8000 Fax: (202) 663-8007 Attorneys for Petitioners Fawzi Khalid Abdullah

CONCLUSION Consistent with the habeas statute and the substantial liberty deprivations at issue in these cases of executive detention, Petitioners are in all cases entitled to discovery and an evidentiary hearing on disputed issues of material fact in which the government must justify its detention by clear and convincing evidence. Because of the equitable and adaptable nature of the habeas remedy and the command of the habeas statute to “dispose of the case as law and justice require,” 28 U.S.C. § 2243, most of the issues related to the scope of discovery, the scope of the confrontation right and the admissibility of hearsay evidence will have to be decided by individual judges based on the facts and circumstances of the particular cases before them. Dated: July 25, 2008 Respectfully submitted, /s/ sdk Shayana D. Kadidal (D.C. Bar No. 454248) J. Wells Dixon CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012 Tel: (212) 614-6438 Case 1:08-cv-00987-UNA Document 19 Filed 07/25/2008 Page 35 of 36 36 Fax: (212) 614-6499 Baher Azmy SETON HALL LAW SCHOOL Center for Social Justice One Newark Center Newark, NJ 07102 Tel: (973) 642-8700 On Behalf of Petitioners David J. Cynamon (D.C. Bar No. 182477) Matthew J. MacLean (D.C. Bar No. 479257) PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, N.W. Washington, DC 20037 Tel: (202) 663-8000 Fax: (202) 663-8007 Attorneys for Petitioners Fawzi Khalid Abdullah