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Geneva Convention Relative to the Treatment of Civilian Persons In Time of War, Aug. 12, 1949 (“Fourth Geneva Convention”), 6 U.S.T. 3516, 75 U.N.T.S. 287, Art. 3, 27, 31, 32, 37, 100, 147 .............. 5 U.S. Army Regulation 190-8, Enemy Prisoners of War, Retained Personnel, Civilian Internees and Other Detainees, §1-5(a)-(c) (Oct. 1, 1997) ..... 6, 11 *U.S. Army Regulation 715-9, Contractors Accompanying the Force (Oct. 29, 1999) ............................................................................. 2, 6, 12, 33 Other Authorities Restatement (Second) of Contracts §203(a) (1981) ..................................... 35 *U.S. Army Field Manual 3-100.21, Contractors on the Battlefield (Jan. 2003) ................................................................................... 6, 34, 2, 12 xvii
GLOSSARY OF ABBREVIATIONS AR U.S. Army Regulation ATS Alien Tort Statute CACI Collectively, CACI International, Inc. and CACI Premier Technology, Inc. COR Contracting Officer’s Representative DoD Department of Defense Fay Report AR 15-6 Investigation of the Abu Ghraib Detention Facility and 205 th Military Intelligence Brigade, Major General George Fay, Investigating Officer (2004) FM U.S. Army Field Manual FTCA Federal Tort Claims Act ICC International Criminal Court ICTR International Criminal Tribunal for Rwanda ICTY International Criminal Tribunal for the Former Yugoslavia L-3 Collectively, Titan Corporation, L-3 Communications Titan Corporation, and L-3 Services, Inc. MG Major General MI Military Intelligence MP Military Police OIC Officer in Charge POC Point of Contact xviii
Page 1 and 2: NOT YET SCHEDULED FOR ORAL ARGUMENT
Page 3 and 4: Juma’a, Kamel Abood Khalaf Al Sam
Page 5 and 6: Hammad Abid Atwan, Jasim Faadhil Ha
Page 7 and 8: Mohammed, Ammar Juma’a Abid, Mali
Page 9 and 10: 08-7008 (D.C. Cir.) have filed a di
Page 11 and 12: B. The District Court Relied on Evi
Page 13 and 14: Cases TABLE OF AUTHORITIES 1010 Pot
Page 15 and 16: In re Tesch (Zyklon B Case), 13 Int
Page 17: West Point Elementary School Teache
Page 21 and 22: STATEMENT OF JURISDICTION The Distr
Page 23 and 24: District of Columbia. The District
Page 25 and 26: Ghraib. Major General Antonio Tagub
Page 27 and 28: employees adhere to United States s
Page 29 and 30: See also Peltier Dep. 156-157; RS.1
Page 31 and 32: Crowley Decl. 5. L-3 told its trans
Page 33 and 34: RS.112, Appendix C-43. L-3 witnesse
Page 35 and 36: (4) Evidence Produced by the Milita
Page 37 and 38: the Iraqi Republican Guard and enem
Page 39 and 40: Rumminger Dep. 167 (Nakhla “spent
Page 41 and 42: military. Finally, as set forth in
Page 43 and 44: preempted only to the extent necess
Page 45 and 46: contract. Id. According to testimon
Page 47 and 48: authority to demand that L-3 transl
Page 49 and 50: SEALED MATERIAL DELETED Third, the
Page 51 and 52: Memorandum prevented L-3 translator
Page 53 and 54: 902, 904 (D.C. Cir. 1992)(summary j
Page 55 and 56: L-3 has produced no evidence from t
Page 57 and 58: (3) L-3’s Self-Serving Litigation
Page 59 and 60: obey operational instructions from
Page 61 and 62: A. The Military Is Opposed to Such
Page 63 and 64: their employees, officers, and subc
Page 65 and 66: community governed by a separate di
Page 67 and 68: not change the fact that it was the
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in Boyle used as a touchstone wheth
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Hudgens v. Bell Helicopters/Textron
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Kellogg, Brown and Root, 444 F.Supp
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Applying the combatant activities e
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applied to insulate the corporate c
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The Supreme Court in Sosa examined
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Doe v. Islamic Salvation Front, 993
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knowing it would be used to kill);
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Respectfully submitted, Susan L. Bu
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ADDENDUM: STATUTES AND REGULATIONS
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Uniform Code of Military Justice, P
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or suffering incidental to lawful s
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laws. Obtaining personal services b
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(c) Outrages upon personal dignity,
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U.S. Army Regulation 190-8, Enemy P
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give directions to their employees.
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CERTIFICATE OF SERVICE Saleh, et al
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