“ In light of respondents’ decision with respect to these five petitioners, further litigation over petitioners’ status is unnecessary and respondents will not file factual returns for these petitioners. Therefore, remedy is the only outstanding issue. Respondents have opposed petitioner Parhat’s motion for release into the United States and will oppose motions for similar relief by the other four similarly situated petitioners. ”

“ Respondents’ counsel advised that they did not believe such an agreement was possible and therefore suggested that Petitioners and Respondents each present their respective views to the Court in separate filings. ↑ Even if Petitioners are released from Guantánamo, the Court must adjudicate their status as “enemy combatants” through habeas hearings because such a designation exposes them to collateral consequences including the stigma of being falsely labeled as terrorists, which jeopardizes their future employability, freedom to travel and freedom from persecution and torture. ”

“ The government has also represented that “it will treat Parhat as if he were no longer an enemy combatant,” a course of action that it believes “should resolve the merits of Parhat’s habeas claim.” Id. at 1-2.
The remaining sixteen Uighur Petitioners are in all material respects identically situated to Parhat. Although they have been approved to leave Guántanamo by the U.S. Department of Defense, each was designated an enemy combatant and has been held in extrajudicial detention since 2002 on the basis of the same core allegations that the D.C. Circuit found wanting against Parhat himself. ”

“ This special camp facility provides significantly more living privileges, including a communal living arrangement, access to all areas of the camp (including a recreation yard, bunk house, and an activity room) , access to entertainment (including a television set equipped with a VCR and DVD, a stereo system, and equipment for soccer, table football (foosball) , and table tennis) , air conditioning in all living areas (which they control) , special food items, and expanded access to shower facilities and library materials. ”

“ Petitioners’ counsel also respectfully request that the Court order Respondents to identify the Camp in which each Uighur Petitioner is currently housed and to notify Petitioners’ counsel within 48 hours following their future transfer to any other Camp within Guantánamo. ”

“ For this reason, the petitioners in Razakah were not included in the parties’ July 21, 2008 Joint Status Report to Judge Hogan. See 08-MC-0442, dkt. no. 170. The status of the two petitioners in the Razakah case is noted in the chart attached hereto as Exhibit 1. ↑ Following the Court’s August 12, 2008 Order, Petitioners’ counsel contacted Respondents’ counsel in an effort to determine whether the parties could reach an agreement on this issue and present a joint response to the Court. ”