TK Complaint to FILE
Case 1:12-cv-01192-RMC Document 3 Filed 07/18/12 Page 1 of 17 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA NASSER AL-AULAQI, as personal representative of the estates of ANWAR AL-AULAQI and ABDULRAHMAN AL-AULAQI c/o American Civil Liberties Union of the Nation’s Capital 4301 Connecticut Avenue, N.W., Suite 434 No. 12-cv-_____ Washington, D.C. 20008, SARAH KHAN, as personal representative of the estate of SAMIR KHAN c/o American Civil Liberties Union of the Nation’s Capital 4301 Connecticut Avenue, N.W., Suite 434 Washington, D.C. 20008, Plaintiffs, v. LEON C. PANETTA, Secretary of Defense 1000 Defense Pentagon Washington, D.C. 20301-1000, WILLIAM H. MCRAVEN, Commander, Special Operations Command 7701 Tampa Point Boulevard MacDill Air Force Base, FL 33621-5323, JOSEPH VOTEL, Commander, Joint Special Operations Command P.O. Box 70239 Fort Bragg, N.C. 28307, DAVID H. PETRAEUS, Director, Central Intelligence Agency Central Intelligence Agency Washington, D.C. 20505, All in their individual capacities, Defendants. Case 1:12-cv-01192-RMC Document 3 Filed 07/18/12 Page 2 of 17 COMPLAINT (Violation of Fourth and Fifth Amendments and Bill of Attainder Clause – targeted killing) INTRODUCTION 1. Since 2001, and routinely since 2009, the United States has carried out deliberate and premeditated killings of suspected terrorists overseas. The U.S. practice of “targeted killing” has resulted in the deaths of thousands of people, including many hundreds of civilian bystanders. While some targeted killings have been carried out in the context of the wars in Afghanistan and Iraq, many have taken place outside the context of armed conflict, in countries including Yemen, Somalia, Pakistan, Sudan, and the Philippines.
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