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106 national lawyers guild reviewdomestic concerns, one can hope that we <strong>have</strong> seen the high tide of Americantorture and that international human rights law will begin to bite._________________notes1. See The Harris Poll #93, Majorities of Public Believe that Torture, “Rendition”and the Use of Secret Prison Camps Outside U.S. are Sometimes Justified, HarrisInteractive, (Dec. 21, 2005), at http://www.harrisinteractive.com/harris poll/index.asp?PID=621(citing American adults’ opinion on whether United States usestorture).2. Id.3. Poll Results: Waterboarding is Torture, CNN.com, at http://www.cnn.com/2007/POLITICS/11/06/waterboard.polllindex.html.4. William Glaberson, 6 at Guantanamo Said to Face Trial in 9/11 Case, N.Y. Times,Feb. 9, 2008, at Al [hereinafter Glaberson, Trial in 9/11 Case].5. Tactic Called Torture, N.Y. Times, Feb. 9, 2008, at A8.6. Martin Hodgson, US Censored for Waterboarding, The Guardian (London), Feb.7, 2008.7. Evan Wallach, Drop by Drop: Forgetting the History of Water Torture in U.S.Courts, 45 Colum. J. Transnat’l L. 468, 472 (2007).8. Id. at 477-94.9. Id. at 502-04.10. Id. at 499.11. Joseph Margulies, Guantanamo and the Abuse of Presidential Power86, 178 (2006), at 6.12. In re Guantanamo Detainee Cases, 355 F. Supp.2d 443, 474 (D. D.C. 2005).13. Ian Robbins, We Have Ways . . . How Do Interrogators Bend People to Their Will?,New Scientist, Nov. 20, 2004, at 44.14. Id.15. Editorial, Modern Barbarity; The Idea That Torture Can Be ‘Clean’ Needs Refuting,New Scientist, Feb. 23, 2008, at 3.16. Id.17. The Bush Administration chooses coercive techniques that would conventionallybe thought of as straightforwardly torturous, including water-boarding, false burial,‘Palestinian hanging’ (where the prisoner is suspended by his arms, manacledbehind his back), being left naked in a cold cell and doused with cold water, andbeing made to stand for forty hours while shackled to a cell floor. Christopher Kutz,Torture, Necessity and Existential Politics, 95 Cal. L. Rev. 235, 235-36 (2007).18. Katerina Ossenova, Spain Judge Drops Extradition Request for UK ResidentsReleased from Guantanamo, Jurist, Mar. 6, 2008, at http://jurist.law.pitt.edu/paperchase/2008/03/spain-judge-drops-extradition-request.php.19. Id.20. Stanley Milgram, Obedience to Authority: An Experimental View(2004).

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