IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

FADI AL-MAQALEH, et al.,

Petitioners,

v.

ROBERT GATES, et al.,

Respondents.

Civil Action No. 06-1669 (JDB)

AMIN AL-BAKRI, et al.,

Petitioners,

v.

BARACK H. OBAMA, et al.,

Respondents.

Civil Action No. 08-1307 (JDB)

REDHA AL-NAJAR, et al.,

Petitioners,

v.

ROBERT GATES, et al.,

Respondents.

Civil Action No. 08-2143 (JDB)

DECLARATION OF RAMZI KASSEM

Pursuant to 28 U.S.C. § 1746, I certify that the following is true and correct to the best of

my knowledge:

1. My name is Ramzi Kassem. I am an attorney admitted to practice law in the State of

New York.

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2. I am lead counsel to Petitioner Amin al-Bakri in the above-captioned matter and submit

this declaration in further support of Petitioners’ memorandum of law and supplemental

materials in opposition to Respondents’ Motion to Dismiss Amended Petitions for Writs

of Habeas Corpus, and in keeping with this Court’s Minute Order of August 28, 2012,

instructing undersigned counsel to file any additional materials by no later than

September 25, 2012.

3. Attached hereto as Exhibit 1 is a letter dated September 19, 2012, issued on official

letterhead by the Office of the President of the Islamic Republic of Afghanistan. The

letter bears the seal of the President of the Islamic Republic of Afghanistan, Hamid

Karzai, and is signed by Abdul Karim Khurram, Chief of Staff to the President. The

letter confirms the Afghan government’s position regarding this Court’s possible exercise

of jurisdiction over the above-captioned cases. Accordingly, it directly informs this

Court’s assessment of any “practical obstacles” related to the Bagram prison’s location

within the sovereign territory of Afghanistan. The original letter is on file with counsel.

4. Attached hereto as Exhibit 2 is the Declaration of Colonel Lawrence B. Wilkerson (Ret.),

dated September 22, 2012. This Declaration supplements Petitioners’ evidence of

Respondents’ use of Bagram for the purpose of evading judicial scrutiny of Petitioners’

imprisonment. The original Declaration is on file with counsel.

5. Attached hereto as Exhibit 3 is the Declaration of Glenn Carle, dated September 24,

2012. This Declaration supplements Petitioners’ evidence of Respondents’ use of

Bagram for the purpose of evading judicial scrutiny of Petitioners’ imprisonment. The

original Declaration is on file with counsel.

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I declare under penalty of perjury that the foregoing is true and correct.

New York, NY

Executed on this 24th day of September, 2012

____/s/_________________ RAMZI KASSEM

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EXHIBIT 1

Letter from the Office of the President of the Islamic Republic of Afghanistan (dated September 19, 2012)

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EXHIBIT 2

Declaration of Colonel Lawrence B. Wilkerson (Ret.) (dated September 22, 2012)

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EXHIBIT 3

Declaration of Glenn Carle (dated September 24, 2012)

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