Plaintiffs' Statement of Undisputed Material Facts - Center for Justice ...

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87. Several weeks later, Mr. Alvarado was taken to a private home where he wasquestioned by two representatives of the United States government: one from the United StatesNavy and the other a member of the FBI. [Alvarado Dep. at 58]RESPONSE:88. The following day, the U.S. representatives administered a polygraph examinationthat confirmed that Mr. Alvarado had been tortured and that he did not participate in theSchaufelberger assassination. [Alvarado Dep. at 63; Cable from Amb. Edwin Corr, April 24,1986 (describing the results of Mr. Alvarado’s polygraph examination) (PL 1580) (attached tothe accompanying memorandum as Exh. K)]RESPONSE:24
Dated: June 24, 2005Respectfully submitted,_________________________________David R. Esquivel (TN Bar No. 21459)BASS, BERRY & SIMS PLCAmSouth Center315 Deaderick Street, Suite 2700Nashville, TN 37238-3001Tel: (615) 742-6200Fax: (615) 742-0405Matthew J. Eisenbrandt (CA Bar No. 217335)CENTER FOR JUSTICE & ACCOUNTABILITY870 Market Street, Suite 684San Francisco, CA 94102Tel: (415) 544-0444Fax: (415) 544-0456Carolyn Patty Blum (MA Bar No. 046880)CENTER FOR JUSTICE & ACCOUNTABILITY291 West 12th StreetNew York, NY 10014Tel: (212) 989-0012Fax: (415) 544-0456Counsel for Plaintiffs25
Page 1: IN THE UNITED STATES DISTRICT COURT
Page 4 and 5: 11. Ms. Chavez returned to her hous
Page 6 and 7: 17. On September 25, 1980, Ms. Sant
Page 8 and 9: 25. Inside the headquarters, she wa
Page 10 and 11: 33. When she replied that did not,
Page 12 and 13: 41. Afterwards, one of Ms. Santos
Page 14 and 15: 49. One of these men, who was weari
Page 16 and 17: 57. The FDR was formed in April 198
Page 18 and 19: E. John Doe (Daniel Alvarado)64. In
Page 20 and 21: 72. They also accused him of respon
Page 22 and 23: ack, hanging him from the ceiling,
Page 26: CERTIFICATE OF SERVICEI hereby cert

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