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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. -
KATALOG Lado 2018 ENG Crveni.Cdr
LADO Celebrating the Richness and Diversity of Croatian Dance and Music LADO National Folk Dance Ensemble of Croatia LADO, an archaic Slavic word, is a synonym for good, kind and nice, and is frequently used as a refrain in ancient ritual songs of north-western Croatia. LADO, the National Folk Dance Ensemble of Croatia, was founded in 1949 in Zagreb as a professional national ensemble, with the aim of researching, artistically interpreting and presenting on stage the most beautiful examples of the rich traditions of Croatian music and dance. The ensemble's brilliant dancers, who are also excellent singers, can easily transform this folk dance ensemble into an impressive folk choir, while its 14 superb musicians play some fifty different traditional and classical instruments. In its repertoire, which consists of more than a hundred different choreographies and several hundred vocal, instrumental and vocal-instrumental numbers, LADO represents the rich and diverse regional musical and choreographic traditions of Croatia, which is geographically situated at a crossroad of Europe in which the Mediterranean, Balkan, Pannonian and Alpine influences are found in the dances, music and costumes. LADO is often called a "Dancing Museum" because of the priceless and beautiful authentic national costumes (more than 1,200 costumes) it has in its collection , some of which are 100 years old. The ensemble also presents new, contemporary musical and choreographic works based on traditional motifs and elements. LADO When My Wedding Party Awakens You - -
Clitic Placement, Syntactic Discontinuity and Information Structure
CLITIC PLACEMENT, SYNTACTIC DISCONTINUITY AND INFORMATION STRUCTURE Damir Cavar and Melanie Seiss Eastern Michigan University Universität Konstanz Proceedings of the LFG11 Conference Miriam Butt and Tracy Holloway King (Editors) 2011 CSLI Publications http://csli-publications.stanford.edu/ Abstract The phenomenon of so-called second position clitics has received con- siderable attention in the linguistic literature, and some proposed analyses of the phenomenon have suggested major architectural changes to linguistic theories. In this paper, we look at second position clitics in New-Shtokavian, their syntactic and prosodic properties, and propose a purely syntactic clitic placement analysis. We show that the complex data can be accounted for by an analysis of split constituents and their resulting information structure differences with a simple prosody-syntax interface. 1 Introduction The phenomenon of so-called second position clitics (2PC) in particular in Slavic languages has received considerable attention in the linguistic literature over the last decades. Some proposed analyses of the phenomenon have led to major ar- chitectural changes to linguistic theories, and new powerful mechanisms, which for many appeared unnecessary and unmotivated, leading to wrong predictions and over-generation. In this paper, we look at second position clitics in New- Shtokavian (NSh), their syntactic and prosodic properties, and propose a purely syntactic clitic placement analysis. NSh in the ije-kavian variant currently represents the Croatian standard language, while the i- and e-kavian variants are spoken in e.g. Bosnia– Herzegovina and Serbia respectively. The examples discussed in the following are from the NSh variant spoken in Croatia.1 The problem we are concerned with in this paper is illustrated by the exam- ples in (1). -
The Impact of the Illyrian Movement on the Croatian Lexicon
Slavistische Beiträge ∙ Band 223 (eBook - Digi20-Retro) George Thomas The Impact of the Illyrian Movement on the Croatian Lexicon Verlag Otto Sagner München ∙ Berlin ∙ Washington D.C. Digitalisiert im Rahmen der Kooperation mit dem DFG-Projekt „Digi20“ der Bayerischen Staatsbibliothek, München. OCR-Bearbeitung und Erstellung des eBooks durch den Verlag Otto Sagner: http://verlag.kubon-sagner.de © bei Verlag Otto Sagner. Eine Verwertung oder Weitergabe der Texte und Abbildungen, insbesondere durch Vervielfältigung, ist ohne vorherige schriftliche Genehmigung des Verlages unzulässig. «Verlag Otto Sagner» ist ein Imprint der Kubon & Sagner GmbH. George Thomas - 9783954792177 Downloaded from PubFactory at 01/10/2019 04:08:27AM via free access 00050383 S lavistische B e it r ä g e BEGRÜNDET VON ALOIS SCHMAUS HERAUSGEGEBEN VON HEINRICH KUNSTMANN PETER REHDER • JOSEF SCHRENK REDAKTION PETER REHDER Band 223 VERLAG OTTO SAGNER MÜNCHEN George Thomas - 9783954792177 Downloaded from PubFactory at 01/10/2019 04:08:27AM via free access 00050383 GEORGE THOMAS THE IMPACT OF THEJLLYRIAN MOVEMENT ON THE CROATIAN LEXICON VERLAG OTTO SAGNER • MÜNCHEN 1988 George Thomas - 9783954792177 Downloaded from PubFactory at 01/10/2019 04:08:27AM via free access ( B*y«ftecne I Staatsbibliothek l Mönchen ISBN 3-87690-392-0 © Verlag Otto Sagner, München 1988 Abteilung der Firma Kubon & Sagner, GeorgeMünchen Thomas - 9783954792177 Downloaded from PubFactory at 01/10/2019 04:08:27AM via free access 00050383 FOR MARGARET George Thomas - 9783954792177 Downloaded from PubFactory at 01/10/2019 04:08:27AM via free access .11 ж ־ י* rs*!! № ri. ur George Thomas - 9783954792177 Downloaded from PubFactory at 01/10/2019 04:08:27AM via free access 00050383 Preface My original intention was to write a book on caiques in Serbo-Croatian. -
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. -
Vladimir-Peter-Goss-The-Beginnings
Vladimir Peter Goss THE BEGINNINGS OF CROATIAN ART Published by Ibis grafika d.o.o. IV. Ravnice 25 Zagreb, Croatia Editor Krešimir Krnic This electronic edition is published in October 2020. This is PDF rendering of epub edition of the same book. ISBN 978-953-7997-97-7 VLADIMIR PETER GOSS THE BEGINNINGS OF CROATIAN ART Zagreb 2020 Contents Author’s Preface ........................................................................................V What is “Croatia”? Space, spirit, nature, culture ....................................1 Rome in Illyricum – the first historical “Pre-Croatian” landscape ...11 Creativity in Croatian Space ..................................................................35 Branimir’s Croatia ...................................................................................75 Zvonimir’s Croatia .................................................................................137 Interlude of the 12th c. and the Croatia of Herceg Koloman ............165 Et in Arcadia Ego ...................................................................................231 The catastrophe of Turkish conquest ..................................................263 Croatia Rediviva ....................................................................................269 Forest City ..............................................................................................277 Literature ................................................................................................303 List of Illustrations ................................................................................324 -
The Production of Lexical Tone in Croatian
The production of lexical tone in Croatian Inauguraldissertation zur Erlangung des Grades eines Doktors der Philosophie im Fachbereich Sprach- und Kulturwissenschaften der Johann Wolfgang Goethe-Universität zu Frankfurt am Main vorgelegt von Jevgenij Zintchenko Jurlina aus Kiew 2018 (Einreichungsjahr) 2019 (Erscheinungsjahr) 1. Gutacher: Prof. Dr. Henning Reetz 2. Gutachter: Prof. Dr. Sven Grawunder Tag der mündlichen Prüfung: 01.11.2018 ABSTRACT Jevgenij Zintchenko Jurlina: The production of lexical tone in Croatian (Under the direction of Prof. Dr. Henning Reetz and Prof. Dr. Sven Grawunder) This dissertation is an investigation of pitch accent, or lexical tone, in standard Croatian. The first chapter presents an in-depth overview of the history of the Croatian language, its relationship to Serbo-Croatian, its dialect groups and pronunciation variants, and general phonology. The second chapter explains the difference between various types of prosodic prominence and describes systems of pitch accent in various languages from different parts of the world: Yucatec Maya, Lithuanian and Limburgian. Following is a detailed account of the history of tone in Serbo-Croatian and Croatian, the specifics of its tonal system, intonational phonology and finally, a review of the most prominent phonetic investigations of tone in that language. The focal point of this dissertation is a production experiment, in which ten native speakers of Croatian from the region of Slavonia were recorded. The material recorded included a diverse selection of monosyllabic, bisyllabic, trisyllabic and quadrisyllabic words, containing all four accents of standard Croatian: short falling, long falling, short rising and long rising. Each target word was spoken in initial, medial and final positions of natural Croatian sentences. -
September – October 2013
123 POINT OF VIEW JEROME’S NEWSLETTER September – October 2013 From the Mayor Without much noise, Jerome quietly passed and enacted to civil rights and ideological tyranny. I find it so a civil union ordinance. No one showed up to the interesting that, thus far, the ideological discomfort of meetings to speak out against, or fervently support this those that oppose gay marriage has been honored over issue… and I know its not because we lack civic the rights of the LGBT community – Which I assume engagement in this town! How wonderful that our town provides ideological discomfort by just existing for some held up no opposition to supporting our delightfully people. It’s silly to think that those bothered will diverse population! magically change their mind on the topic, but it is So, what have we done? How is it different than simply outrageous to continue to deny basic rights to a marriage? How will the rest of Arizona respond? Our section of the population. civil union ordinance is certainly not as broad as a proper And so, dear residents, I hope that you can all be proud marriage. First, it isn’t accompanied by marriage & of what Jerome has accomplished here, and I hope to divorce law, which maps out alimony and such. It does, have your continued support, even if we receive some however provide room for a committed, previously negative attention for enacting this ordinance. Thank unmarried couple to scribble down some agreements You! about property, finances, and medical care and have it Mayor Nikki Check available on file in the Town of Jerome for a one-time fee of $73. -
Eight Fragments Serbian, Croatian, Bosnian
EIGHT FRAGMENTS FROM THE WORLD OF MONTENEGRIN LANGUAGES AND SERBIAN, CROATIAN, SERBIAN, CROATIAN, BOSNIAN SERBIAN, CROATIAN, BOSNIAN AND FROM THE WORLD OF MONTENEGRIN EIGHT FRAGMENTS LANGUAGES Pavel Krejčí PAVEL KREJČÍ PAVEL Masaryk University Brno 2018 EIGHT FRAGMENTS FROM THE WORLD OF SERBIAN, CROATIAN, BOSNIAN AND MONTENEGRIN LANGUAGES Selected South Slavonic Studies 1 Pavel Krejčí Masaryk University Brno 2018 All rights reserved. No part of this e-book may be reproduced or transmitted in any form or by any means without prior written permission of copyright administrator which can be contacted at Masaryk University Press, Žerotínovo náměstí 9, 601 77 Brno. Scientific reviewers: Ass. Prof. Boryan Yanev, Ph.D. (Plovdiv University “Paisii Hilendarski”) Roman Madecki, Ph.D. (Masaryk University, Brno) This book was written at Masaryk University as part of the project “Slavistika mezi generacemi: doktorská dílna” number MUNI/A/0956/2017 with the support of the Specific University Research Grant, as provided by the Ministry of Education, Youth and Sports of the Czech Republic in the year 2018. © 2018 Masarykova univerzita ISBN 978-80-210-8992-1 ISBN 978-80-210-8991-4 (paperback) CONTENT ABBREVIATIONS ................................................................................................. 5 INTRODUCTION ................................................................................................. 7 CHAPTER 1 SOUTH SLAVONIC LANGUAGES (GENERAL OVERVIEW) ............................... 9 CHAPTER 2 SELECTED CZECH HANDBOOKS OF SERBO-CROATIAN -
'Race' and Diaspora: Romani Music Making in Ostrava, Czech Republic
Music, ‘Race’ and Diaspora: Romani Music Making in Ostrava, Czech Republic Melissa Wynne Elliott 2005 School of Oriental and African Studies University of London PhD ProQuest Number: 10731268 All rights reserved INFORMATION TO ALL USERS The quality of this reproduction is dependent upon the quality of the copy submitted. In the unlikely event that the author did not send a com plete manuscript and there are missing pages, these will be noted. Also, if material had to be removed, a note will indicate the deletion. uest ProQuest 10731268 Published by ProQuest LLC(2017). Copyright of the Dissertation is held by the Author. All rights reserved. This work is protected against unauthorized copying under Title 17, United States C ode Microform Edition © ProQuest LLC. ProQuest LLC. 789 East Eisenhower Parkway P.O. Box 1346 Ann Arbor, Ml 48106- 1346 Abstract This thesis is a contribution towards an historically informed understanding of contemporary music making amongst Roma in Ostrava, Czech Republic. It also challenges, from a theoretical perspective, conceptions of relationships between music and discourses of ‘race’. My research is based on fieldwork conducted in Ostrava, between August 2003 and July 2004 and East Slovakia in July 2004, as well as archival research in Ostrava and Vienna. These fieldwork experiences compelled me to explore music and ideas of ‘race’ through discourses of diaspora in order to assist in conceptualising and interpreting Romani music making in Ostrava. The vast majority of Roma in Ostrava are post-World War II emigres or descendants of emigres from East Slovakia. In contemporary Ostrava, most Roma live on the socio economic margins and are most often regarded as a separate ‘race’ with a separate culture from the dominant population. -
“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. -
Language in Croatia: Influenced by Nationalism
Language in Croatia: Influenced by Nationalism Senior Essay Department of Linguistics, Yale University CatherineM. Dolan Primary Advisor: Prof. Robert D. Greenberg Secondary Advisor: Prof. Dianne Jonas May 1, 2006 Abstract Language and nationalism are closely linked, and this paper examines the relationship between the two. Nationalism is seen to be a powerful force which is capable ofusing language for political purposes, and the field oflinguistics has developed terminology with which the interface oflanguage and nationalism maybe studied. Using this background, the language situation in Croatia may be examined and seen to be complex. Even after thorough evaluation it is difficult to determine how languages and dialects should be delineated in Croatia, but it is certain that nationalism and politics play key roles in promoting the nation's linguistic ideals. 2 , Acknowledgements I suppose I could say that this essay was birthed almost two years ago, when I spent the summer traveling with a group ofstudents throughout Croatia, Bosnia and Serbia in order to study issues ofjustice and reconciliation. Had I never traveled in the region I may have never gained an interest in the people, their history and, yes, their language(s). Even after conducting a rigorous academic study ofthe issues plaguing former Socialist Federal Republic ofYugoslavia, I carry with me the impression that this topic can never be taken entirely into the intellectual realm; I am reminded by my memories that the Balkan conflicts involve people just as real as myself. For this, I thank all those who shared those six weeks oftraveling. That summer gave me new perspectives on many areas oflife.