Padilla Reply Brief and Exibits on Motion Alleging Outrageous Government Conduct

John Young kindly collects the links (and has some good pictures):

1 Main Document 10
pages
Mr. Padilla’s Reply to the Government’s Response to the Motion
to Dismiss for Outrageous Government Conduct

2 Exhibit A 1 page
Affidavit of Jose Padilla

3 Exhibit B 5 pages

Affidavit of Angela Hegarty, MD

4 Exhibit C 4 pages
Stuart Grassian, MD, Overview: Neuropsychiatric Effects of Solitary Confinement

5 Exhibit D 7 pages
Declaration of Andrew G. Patel, Attorney

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2 Responses to Padilla Reply Brief and Exibits on Motion Alleging Outrageous Government Conduct

  1. Patrick (G) says:

    “The government also claims that Mr. Padilla was treated humanely during his detention as an enemy combatant. This unsupported claim is also false.”

    “Finally, Mr. Padilla has also reiterated his demand that the government fully comply with this Court’s Order, DE 572, compelling the government to turn over records generated during Mr. Padilla’s
    confinement. This Court ordered the government’s compliance within thirty days of September
    14, 2006. Id. As of this filing, almost eighty days have elapsed since September 14 and the
    government still has not fully complied with this Court’s Order.”

    At this point, it sounds like there needs to be an evidentiary hearing, not to ascertain Mr. Padilla’s credibility but the government’s. If the Government (i.e. the Navy) is unwilling or unable to provide full documentation of Mr. Padilla’s treatment while in Navy custody, then they cannot credibly contradict Mr. Padilla’s claims of mistreatment.

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