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We should reply to the Government's answer as soon as possible, since our
writ appeal won't be circulated for decision until we reply. We're hoping
that if it's circulated soon, Chief Judge Effron will take part in its
consideration. (If he chose to, he could even continue to participate in
the case as a Senior Judge after 30 September.)
Attached is a VERY, VERY rough draft. I haven't even proof read what
I wrote and I was pretty pissed at the government while writing it, so it will
probably have to be toned down. But this will get us started. I
don't see any reason why we can't file on Wednesday.
Right now it's 3,500 words. Our limit is 7.000. So we shouldn't
have any problem with length.
Please chop away.
Semper Fi, DHS |
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Wuterich writ appeal reply (12 Sep 2011) draft 1.docx
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