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Reply Memorandum of Law in Support of Motion to Unseal by Raymond Bonner
Case 1:08-cv-01360-UNA Document 436 Filed 11/07/16 Page 1 of 32 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ZAYN AL ABIDIN MUHAMMAD ) HUSAYN (ISN # 10016), ) ) Petitioner. ) ) v. ) No. 08-CV-1360 ) ASHTON CARTER, ) ) Respondent. ) ) REPLY MEMORANDUM OF LAW IN SUPPORT OF MOTION TO UNSEAL BY RAYMOND BONNER David A. Schulz Hannah Bloch-Wehba Steven Lance (law student intern) Andrew Udelsman (law student intern) Media Freedom & Information Access Clinic Abrams Institute for Freedom of Expression Yale Law School P.O. Box 208215 New Haven, CT 06520 Phone: 212-850-6103 Fax: 212-850-6299 Chad Bowman Levine Sullivan Koch & Schulz, LLP 1899 L Street, NW, Suite 200 Washington, DC 20036 Phone: 202-508-1100 Fax: 202-861-8988 Counsel for Movant Raymond Bonner Case 1:08-cv-01360-UNA Document 436 Filed 11/07/16 Page 2 of 32 TABLE OF CONTENTS PRELIMINARY STATEMENT .................................................................................................... 1 ARGUMENT .................................................................................................................................. 2 I. JUDICIAL RECORDS ARE SUBJECT TO THE FIRST AMENDMENT RIGHT OF ACCESS, EVEN WHEN THEY CONTAIN CLASSIFIED INFORMATION .......... 2 A. Classified Information Is Not Exempt From the Constitutional Access Right ....... 2 1. The government misapplies the “history and logic” test to the content of a record rather than the type of proceeding involved. ............... 2 2. The unilateral Executive authority to seal court records claimed by the government would violate the constitutional separation of powers. ..... 5 B. The Constitutional Standard Must Be Satisfied To Seal A Court Record That Contains Classified Information ..................................................................... 6 1. The Executive’s classification standards do not automatically satisfy the controlling First Amendment standard. -
February 26, 2021 Amazon Warehouse Workers In
February 26, 2021 Amazon warehouse workers in Bessemer, Alabama are voting to form a union with the Retail, Wholesale and Department Store Union (RWDSU). We are the writers of feature films and television series. All of our work is done under union contracts whether it appears on Amazon Prime, a different streaming service, or a television network. Unions protect workers with essential rights and benefits. Most importantly, a union gives employees a seat at the table to negotiate fair pay, scheduling and more workplace policies. Deadline Amazon accepts unions for entertainment workers, and we believe warehouse workers deserve the same respect in the workplace. We strongly urge all Amazon warehouse workers in Bessemer to VOTE UNION YES. In solidarity and support, Megan Abbott (DARE ME) Chris Abbott (LITTLE HOUSE ON THE PRAIRIE; CAGNEY AND LACEY; MAGNUM, PI; HIGH SIERRA SEARCH AND RESCUE; DR. QUINN, MEDICINE WOMAN; LEGACY; DIAGNOSIS, MURDER; BOLD AND THE BEAUTIFUL; YOUNG AND THE RESTLESS) Melanie Abdoun (BLACK MOVIE AWARDS; BET ABFF HONORS) John Aboud (HOME ECONOMICS; CLOSE ENOUGH; A FUTILE AND STUPID GESTURE; CHILDRENS HOSPITAL; PENGUINS OF MADAGASCAR; LEVERAGE) Jay Abramowitz (FULL HOUSE; GROWING PAINS; THE HOGAN FAMILY; THE PARKERS) David Abramowitz (HIGHLANDER; MACGYVER; CAGNEY AND LACEY; BUCK JAMES; JAKE AND THE FAT MAN; SPENSER FOR HIRE) Gayle Abrams (FRASIER; GILMORE GIRLS) 1 of 72 Jessica Abrams (WATCH OVER ME; PROFILER; KNOCKING ON DOORS) Kristen Acimovic (THE OPPOSITION WITH JORDAN KLEPPER) Nick Adams (NEW GIRL; BOJACK HORSEMAN; -
Ethnicity and the Political Reconstruction of Afghanistan
A Service of Leibniz-Informationszentrum econstor Wirtschaft Leibniz Information Centre Make Your Publications Visible. zbw for Economics Schetter, Conrad Working Paper Ethnicity and the political reconstruction of Afghanistan ZEF Working Paper Series, No. 3 Provided in Cooperation with: Zentrum für Entwicklungsforschung / Center for Development Research (ZEF), University of Bonn Suggested Citation: Schetter, Conrad (2005) : Ethnicity and the political reconstruction of Afghanistan, ZEF Working Paper Series, No. 3, University of Bonn, Center for Development Research (ZEF), Bonn, http://nbn-resolving.de/urn:nbn:de:0202-2008091124 This Version is available at: http://hdl.handle.net/10419/88366 Standard-Nutzungsbedingungen: Terms of use: Die Dokumente auf EconStor dürfen zu eigenen wissenschaftlichen Documents in EconStor may be saved and copied for your Zwecken und zum Privatgebrauch gespeichert und kopiert werden. personal and scholarly purposes. Sie dürfen die Dokumente nicht für öffentliche oder kommerzielle You are not to copy documents for public or commercial Zwecke vervielfältigen, öffentlich ausstellen, öffentlich zugänglich purposes, to exhibit the documents publicly, to make them machen, vertreiben oder anderweitig nutzen. publicly available on the internet, or to distribute or otherwise use the documents in public. Sofern die Verfasser die Dokumente unter Open-Content-Lizenzen (insbesondere CC-Lizenzen) zur Verfügung gestellt haben sollten, If the documents have been made available under an Open gelten abweichend von diesen Nutzungsbedingungen -
Edward R. Murrow
Edward R. Murrow Edward Roscoe Murrow (April 25, 1908 – April 27, 1965), born Egbert Roscoe Murrow,[1] was an American broadcast journalist and war correspondent. He first gained Edward R. Murrow prominence during World War II with a series of live radio broadcasts from Europe for the news division of CBS. During the war he recruited and worked closely with a team of war correspondents who came to be known as the Murrow Boys. A pioneer of radio and television news broadcasting, Murrow produced a series of reports on his television program See It Now which helped lead to the censure of Senator Joseph McCarthy. Fellow journalists Eric Sevareid, Ed Bliss, Bill Downs, Dan Rather, and Alexander Kendrick consider Murrow one of journalism's greatest figures, noting his honesty and integrity in delivering the news. Contents Early life Career at CBS Radio Murrow in 1961 World War II Born Egbert Postwar broadcasting career Radio Roscoe Television and films Murrow Criticism of McCarthyism April 25, Later television career Fall from favor 1908 Summary of television work Guilford United States Information Agency (USIA) Director County, North Death Carolina, Honors U.S. Legacy Works Died April 27, Filmography 1965 Books (aged 57) References Pawling, New External links and references Biographies and articles York, U.S. Programs Resting Glen Arden place Farm Early life 41°34′15.7″N 73°36′33.6″W Murrow was born Egbert Roscoe Murrow at Polecat Creek, near Greensboro,[2] in Guilford County, North Carolina, the son of Roscoe Conklin Murrow and Ethel F. (née Lamb) Alma mater Washington [3] Murrow. -
The Oath a Film by Laura Poitras
The Oath A film by Laura Poitras POV www.pbs.org/pov DISCUSSION GUIDe The Oath POV Letter frOm the fiLmmakers New YorK , 2010 I was first interested in making a film about Guantanamo in 2003, when I was also beginning a film about the war in Iraq. I never imagined Guantanamo would still be open when I finished that film, but sadly it was — and still is today. originally, my idea for the Oath was to make a film about some - one released from Guantanamo and returning home. In May 2007, I traveled to Yemen looking to find that story and that’s when I met Abu Jandal, osama bin Laden’s former bodyguard, driving a taxicab in Sana’a, the capital of Yemen. I wasn’t look - ing to make a film about Al-Qaeda, but that changed when I met Abu Jandal. Themes of betrayal, guilt, loyalty, family and absence are not typically things that come to mind when we imagine a film about Al-Qaeda and Guantanamo. Despite the dangers of telling this story, it compelled me. Born in Saudi Arabia of Yemeni parents, Abu Jandal left home in 1993 to fight jihad in Bosnia. In 1996 he recruited Salim Ham - dan to join him for jihad in Tajikistan. while traveling through Laura Poitras, filmmaker of the Oath . Afghanistan, they were recruited by osama bin Laden. Abu Jan - Photo by Khalid Al Mahdi dal became bin Laden's personal bodyguard and “emir of Hos - pitality.” Salim Hamdan became bin Laden’s driver. Abu Jandal ends up driving a taxi and Hamdan ends up at Guantanamo. -
Orville Schell
The Death of Engagment: America’s New Cold War with China | Orville Schell July 29th, 2020 INTRODUCTION Orville Schell is the Arthur Ross Director of the Center on U.S.-China Relations at Asia Society in New York. He is a former professor and Dean at the University of California, Berkeley Graduate School of Journalism. Schell is the author of fifteen books, ten of them about China, contributed to numerous edited volumes and has written widely for many magazine and newspapers, including The Atlantic Monthly, The New Yorker, Time, The New Republic, Harpers, The Nation, The New York Review of Books, Wired, Foreign Affairs, the China Quarterly, and The New York Times, the Washington Post, and the Los Angeles Times. Schell was born in New York City, graduated Magna Cum Laude from Harvard University in Far Eastern History, was an exchange student at National Taiwan University in the 1960s, and earned a Ph.D. (Abd) at University of California, Berkeley in Chinese History. He worked for the Ford Foundation in Indonesia, covered the war in Indochina as a journalist, and has traveled widely in China since the mid-70s. He is a Fellow at the Weatherhead East Asian Institute at Columbia University, a Senior Fellow at the Annenberg School of Communications at USC and a member of the Council on Foreign Relations. Schell is also the recipient of many prizes and fellowships, including a Guggenheim Fellowship, the Overseas Press Club Award, and the Harvard-Stanford Shorenstein Prize in Asian Journalism. WHY DO I CARE? I’m very concerned about the precipitous deterioration of relations between the United States and China. -
N Ieman Reports
NIEMAN REPORTS Nieman Reports One Francis Avenue Cambridge, Massachusetts 02138 Nieman Reports THE NIEMAN FOUNDATION FOR JOURNALISM AT HARVARD UNIVERSITY VOL. 62 NO. 1 SPRING 2008 VOL. 62 NO. 1 SPRING 2008 21 ST CENTURY MUCKRAKERS THE NIEMAN FOUNDATION HARVARDAT UNIVERSITY 21st Century Muckrakers Who Are They? How Do They Do Their Work? Words & Reflections: Secrets, Sources and Silencing Watchdogs Journalism 2.0 End Note went to the Carnegie Endowment in New York but of the Oakland Tribune, and Maynard was throw- found times to return to Cambridge—like many, ing out questions fast and furiously about my civil I had “withdrawal symptoms” after my Harvard rights coverage. I realized my interview was lasting ‘to promote and elevate the year—and would meet with Tenney. She came to longer than most, and I wondered, “Is he trying to my wedding in Toronto in 1984, and we tried to knock me out of competition?” Then I happened to keep in touch regularly. Several of our class, Peggy glance over at Tenney and got the only smile from standards of journalism’ Simpson, Peggy Engel, Kat Harting, and Nancy the group—and a warm, welcoming one it was. I Day visited Tenney in her assisted living facility felt calmer. Finally, when the interview ended, I in Cambridge some years ago, during a Nieman am happy to say, Maynard leaped out of his chair reunion. She cared little about her own problems and hugged me. Agnes Wahl Nieman and was always interested in others. Curator Jim Tenney was a unique woman, and I thoroughly Thomson was the public and intellectual face of enjoyed her friendship. -
Authority Stealing 00A Adebanwi Fmt 11/23/11 12:01 PM Page Ii
00a adebanwi fmt 11/23/11 12:01 PM Page i Authority Stealing 00a adebanwi fmt 11/23/11 12:01 PM Page ii Carolina Academic Press African World Series Toyin Falola, Series Editor Africa, Empire and Globalization: Essays in Honor of A. G. Hopkins Toyin Falola, editor, and Emily Brownell, editor African Entrepreneurship in Jos, Central Nigeria, 1902 –1985 S.U. Fwatshak An African Music and Dance Curriculum Model: Performing Arts in Education Modesto Amegago Authority Stealing: Anti-Corruption War and Democratic Politics in Post-Military Nigeria Wale Adebanwi The Bukusu of Kenya: Folktales, Culture and Social Identities Namulundah Florence Democracy in Africa: Political Changes and Challenges Saliba Sarsar, editor, and Julius O. Adekunle, editor Diaspora and Imagined Nationality: USA-Africa Dialogue and Cyberframing Nigerian Nationhood Koleade Odutola 00a adebanwi fmt 11/23/11 12:01 PM Page iii Food Crop Production, Hunger, and Rural Poverty in Nigeria’s Benue Area, 1920 –1995 Mike Odugbo Odey Intercourse and Crosscurrents in the Atlantic World: Calabar-British Experience, 17th –20th Centuries David Lishilinimle Imbua Perspectives on Feminism in Africa ‘Lai Olurode, editor Pioneer, Patriot, and Nigerian Nationalist: A Biography of the Reverend M. D. Opara, 1915 –1965 Felix Ekechi The Tiv and Their Southern Neighbours, 1890 –1990 Emmanuel Chiahemba Ayanga ôr The Women’s War of 1929: A History of Anti-Colonial Resistance in Eastern Nigeria Toyin Falola and Adam Paddock The Yoruba Frontier: A Regional History of Community Formation, Experience, and Changes in West Africa Aribidesi Usman 00a adebanwi fmt 11/23/11 12:01 PM Page iv 00a adebanwi fmt 11/23/11 12:01 PM Page v Authority Stealing Anti-Corruption War and Democratic Politics in Post-Military Nigeria Wale Adebanwi Carolina Academic Press Durham, North Carolina 00a adebanwi fmt 11/23/11 12:01 PM Page vi Copyright © 2012 Wale Adebanwi All Rights Reserved Library of Congress Cataloging-in-Publication Data Adebanwi, Wale. -
What I Read on My Summer Vacation (IV) Ron Javers
University of Nebraska - Lincoln DigitalCommons@University of Nebraska - Lincoln The hinC a Beat Blog Archive 2008-2012 China Beat Archive 2010 What I Read on My Summer Vacation (IV) Ron Javers Follow this and additional works at: https://digitalcommons.unl.edu/chinabeatarchive Part of the Asian History Commons, Asian Studies Commons, Chinese Studies Commons, and the International Relations Commons Javers, Ron, "What I Read on My Summer Vacation (IV)" (2010). The China Beat Blog Archive 2008-2012. 857. https://digitalcommons.unl.edu/chinabeatarchive/857 This Article is brought to you for free and open access by the China Beat Archive at DigitalCommons@University of Nebraska - Lincoln. It has been accepted for inclusion in The hinC a Beat Blog Archive 2008-2012 by an authorized administrator of DigitalCommons@University of Nebraska - Lincoln. What I Read on My Summer Vacation (IV) September 28, 2010 in Books by The China Beat | Permalink By Ron Javers I was booked to give a China talk in August, high season in the Hamptons, as part of the summer series at the Rogers Memorial Library in Southampton. You never know who’s going to show up for these well-attended sessions—Southampton summer residents number everybody from Henry Kissinger to George Soros to Madonna, who made headlines this season when she plunked down $500k to rent a place for just one month. (Well, it was beachfront.) I decided to title the talk “Five Things Americans Need to Know about China—Now.” And then, since the venue was a library, I tacked on “…and Six Books that Will Deepen Your Knowledge.” My plan was to scour my dusty shelves for a half-dozen China books I had read—whether months ago or years ago didn’t make any difference, but to make the cut the books had to have lingered in my mind, which can be a difficult task for any book. -
“New Norms” and the Continuing Relevance of IHL in the Post-9/11
International Review of the Red Cross (2015), 97 (900), 1277–1293. The evolution of warfare doi:10.1017/S1816383116000138 The danger of “new norms” and the continuing relevance of IHL in the post-9/11 era Anna Di Lellio and Emanuele Castano Anna Di Lellio is a Professor of International Affairs at the New School of Public Engagement and New York University. Emanuele Castano is a Professor of Psychology at the New School for Social Research. Abstract In the post-9/11 era, the label “asymmetric wars” has often been used to question the relevance of certain aspects of international humanitarian law (IHL); to push for redefining the combatant/civilian distinction; and to try to reverse accepted norms such as the bans on torture and assassination. In this piece, we focused on legal and policy discussions in the United States and Israel because they better illustrate the dynamics of State-led “norm entrepreneurship”, or the attempt to propose opposing or modified norms as a revision of IHL. We argue that although these developments are to be taken seriously, they have not weakened the normative power of IHL or made it passé. On the contrary, they have made it more relevant than ever. IHL is not just a complex (and increasingly sophisticated) branch of law detached from reality. Rather, it is the embodiment of widely shared principles of morality and ethics, and stands as a normative “guardian” against processes of moral disengagement that make torture and the acceptance of civilian deaths more palatable. Keywords: IHL, asymmetric war, norm entrepreneurs, targeted killing, torture, terrorism, moral disengagement. -
Course Correction: Toward an Effective and Sustainable China Policy
COURSE CORRECTION: TOWARD AN EFFECTIVE AND SUSTAINABLE CHINA POLICY Task Force Report Orville Schell and Susan L. Shirk, Chairs February 2019 COURSE CORRECTION: Toward an Effective and Sustainable China Policy 1 COURSE CORRECTION: TOWARD AN EFFECTIVE AND SUSTAINABLE CHINA POLICY Task Force Report Orville Schell and Susan L. Shirk, Chairs February 2019 AsiaSociety.org/USChinaTaskForce PARTNER2 COURSE CORRECTIONORGANIZATIONS: Toward an Effective and Sustainable China Policy The Center on U.S.-China Relations was founded in 2006 and is based at Asia Society’s New York headquarters. The center undertakes projects and events which explore areas of common interest and divergent views between the two countries, focusing on policy, culture, business, media, economics, energy, and the environment. The 21st Century China Center was established in 2011 at the University of California San Diego School of Global Policy and Strategy. It is a leading university-based think tank that uses original research to anchor major policy discussions on China and U.S.-China relations. IN COLLABORATION WITH The Annenberg Foundation Trust at Sunnylands is an independent nonpartisan, nonprofit organization dedicated to convening global leaders in the public, private, and nonprofit sectors to promote world peace, facilitate international agreement, and seek solutions to the most difficult challenges facing the world today. © 2019 Asia Society. All rights reserved. Asia Society Center on U.S.-China Relations 725 Park Avenue New York, NY 10021 212-288-6400 AsiaSociety.org/ChinaCenter The Asia Society Center on U.S.-China Relations and the Asia Society take no institutional positions on matters of public policy and other issues addressed in the reports and publications they sponsor. -
Coming Distractions: Speaking to History
University of Nebraska - Lincoln DigitalCommons@University of Nebraska - Lincoln The hinC a Beat Blog Archive 2008-2012 China Beat Archive 9-26-2008 Coming Distractions: Speaking to History Follow this and additional works at: http://digitalcommons.unl.edu/chinabeatarchive Part of the Asian History Commons, Asian Studies Commons, Chinese Studies Commons, and the International Relations Commons "Coming Distractions: Speaking to History" (2008). The China Beat Blog Archive 2008-2012. 327. http://digitalcommons.unl.edu/chinabeatarchive/327 This Article is brought to you for free and open access by the China Beat Archive at DigitalCommons@University of Nebraska - Lincoln. It has been accepted for inclusion in The hinC a Beat Blog Archive 2008-2012 by an authorized administrator of DigitalCommons@University of Nebraska - Lincoln. Coming Distractions: Speaking to History September 26, 2008 in Coming Distractions by The China Beat | No comments Paul A. Cohen, professor of history emeritus at Wellesley College and also an associate at the Harvard Fairbank Center, has long been interested in not justwhat happened but also how historians tell the stories of the past. As one of the strongest advocates for China-centered historical work, Cohen has explored this tension between history and its telling in works that sometimes reveal unknown stories and sometimes confound the traditional tellings of well-known historical events. These earlier works include China Unbound: Evolving Perspectives on the Chinese Past, History in Three Keys: The Boxers as Event, Experience, and Myth,China and Christianity, and Discovering History in China. Because of the summer’s rise in coverage of Chinese nationalism and its relationship to notions of “national humiliation,” a subject about which Cohen has written, we got in touch with Cohen to chat about current politics as well his forthcoming book from UC Press, Speaking to History: The Story of King Goujian in Twentieth-Century China.