William Kuebler

“ It takes a minimum of one day to travel to Guantanamo Bay and one day to return. The Defense is currently scheduled to return on 14 July, but flights to and fiom Guantanarno Bay are frequently cancelled or rescheduled. Further, just scheduling the trip is difficult. In addition to coordinating dates with Mr. Edney's availability, arranging a trip to Guantanamo Bay requires government transportation to be available as well as JTFGTMO approval to meet with the client. There are a limited number of flights a week to GTMO and counsel are permitted to fly only on a strictly space available basis. ”

“ If desired by either the prosecution or the Court, the undersigned will provide a supporting affidavit.↑ Judge Rolph attempted to distribute a copy of this Court's rules to the defense on 28 June 2007. However, due to a typographical error in the e-mail's "To" block, this email was not actually received in the Office of Military Commissions defense office until 9 July 2007, when Mr. Lee Foreman forwarded it to the Chief Defense Counsel. Foreman email of 9 Ju107 (attachment A) . The defense does not allege any bad faith as a result of what was obviously an innocent mistake. ”

“ Today, seven days after the Court received the Government's brief, the Court ordered the Defense to file any responsive pleading within seven days.
The detailed appellate defense counsel and Mr. Dennis Edney, a Foreign Attorney Consultant for Mr. Khadr, are scheduled to fly to Guantanamo Bay tomorrow at 1200 to meet with Mr. Khadr. See Order No. DFTD70728 for Kuebler (attachment C) . In fact, Mr. Edney is currently traveling from Toronto, Canada to Washington, DC for the flight to Guantanamo Bay. Mr. ”