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CENTER FOR CONSTITUTIONAL RIGHTS
Barbara J. Olshansky (BO 3635)
Nancy Chang (NC 5331)
William Goodman (WG 1241)
Jennifer Green (JG 3169)
Robert T. Perry (RP 1199)
Michael Ratner (MR 3357)
666 Broadway, 7'h Floor
New York, New York 10012
(212) 614-6439 or 614-6420
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
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IBRAHIM TURKMEN; ASIF-UR-REHMAN :
SAFFI; and SYED AMJAD ALI JAFFRI, on :
behalf of themselves and all others
similarly situated,
Plaintiffs, I
- against -
JOHN ASHCROFT, Attorney General of the :
United States; ROBERT MUELLER, Director, :
Federal Bureau of Investigations; JAMES W. :
ZIGLAR, Commissioner, Immigration and
Naturalization Service; Dennis Hasty, Warden, :
Metropolitan Detention Center; and
JOHN DOES I-IO, MDC Corrections Officers, :
Defendants. :
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Plaintiffs lbrahim Turkmen, Asif-ur-Rehman
and through their attorneys, the Center for Constitutional Rights,
NATURE OF ACTION
1. Plaintiffs bring this class action on behalf of
Muslim non-citizens from the Middle East, South Asia, and elsewhere
detained after the September 11, 2001 terrorist attacks on the United
SNIPPETS:
New York, New York 10012
UNITED STATES DISTRICT COURT
JOHN DOES I-IO, MDC Corrections Officers,:
despite receiving final deportation orders or grants of voluntary departure,
held in immigration custody far beyond the period necessary to secure their removal
adopting, promulgating, and implementing this policy, Defendants John Ashcroft, Robert
Mueller, James Ziglar, and others have intentionally or recklessly violated rights
guaranteed to Plaintiffs and class members by the Fourth, Fifth, and Sixth Amendments
While in detention, Plaintiffs and class members have been subjected to
criminal pretrial detainees, even though they themselves have never been charged with
Mueller, Ziglar, Hasty, and John Does I-IO, MDC corrections officers, have intentionally
Fourth, and Fifth Amendments to the United States Constitution, and under customary
award of costs and reasonable attorneys' fees.
Venue is proper in the United States District Court for the Eastern District
voluntary departure order, after an Immigration Judge assured him that he could shortly
that he had any involvement in the September 1 Ith terrorist attacks,
Mr. Turkmen has never been involved with terrorists,
County Jail in Paterson, New Jersey, where he was:
observing certain mandatory religious practices.
shackling, manacling, and physical abuse during cell removals;
unreasonable and excessively harsh conditions in violation of the Constitution.
Muslim non-citizens from the Middle East, South Asia and elsewhere, who have been:
process of law in violation of the Fifth Amendment by detaining them
until they have received two "clearances" -- one from the FBI and the other from INS
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