AN EXPLANATION OF THE FACTIONS  
 

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TEXT OF AL FAYED'S LAWSUIT Part Three

Posted By: Rayelan
Date: Saturday, 2-Sep-2000 16:02:27

In Response To: TEXT OF AL FAYED'S LAWSUIT Part Two (Rayelan)

COUNT EIGHT (EOUSA FOIA REQUEST)

154. Al Fayed and Punch repeat and reallege the allegations contained in paragraphs 1 through 68 above, inclusive.

155. By letter dated July 27, 2000, Al Fayed and Punch, through counsel, submitted a FOIA request for disclosure of all information pertaining to twenty categories of names and events related to the August 31, 1997, deaths of Princess Diana, Dodi Al Fayed and Henri Paul. See Exhibit "1". The request additionally sought expedited processing and a fee waiver. The EOUSA was specifically instructed to search its files within the District of Columbia, Southern District of New York, Central District of California and Eastern District of New York.

156. By letters dated August 8, 2000, the EOUSA indicated it had assigned these requests by categories of "deceased third parties" (00-2565 through 00-2568), "French Inquiry" (00-2569 through 00-2572), "Mohamed Al Fayed" (00-2573 through 00-2576) and "living third parties" (00-2577 through 00-2580). Each category was assigned a number correlating with the District of Columbia, Southern District of New York, Central District of California and Eastern District of New York, respectively.

157. By letter dated August 8, 2000, the EOUSA denied Al Fayed and Punch's request for a fee waiver.

158. By letter dated August 14, 2000, Al Fayed and Punch submitted additional information concerning Keith Fleer, Esq. and Oswald LeWinter, see Exhibit "2", and identified Lisa Prager, Assistant U.S. Attorney, Transnational/Major Crimes Section, District of Columbia, William Blier, Chief, Transnational/Major Crimes Section, District of Columbia, Wilma E. Lewis, United States Attorney, District of Columbia and Rhonda Field, Chief of Staff, Office of the United States Attorney, District of Columbia, as individuals who likely possesses responsive information.

159. By letter dated August 17, 2000, Al Fayed and Punch, through counsel, submitted a FOIA request for records pertaining to John Leslie Macnamara, as well as requested a fee waiver and expedited processing. All prior instructions were incorporated into this request.

160. No further response has been received by the EOUSA.

161. The EOUSA has failed to comply with the requisite statutory periods that govern compliance under the FOIA. Therefore, the EOUSA has wrongfully withheld records from Al Fayed and Punch.

162. Al Fayed and Punch are not required to exhaust administrative remedies as the EOUSA has not issued a formal determination regarding the records.

163. Al Fayed and Punch have a legal right under the FOIA to be granted expedited processing, a fee waiver, and to obtain the information they seek, and there is no legal basis for the denial by the EOUSA of said right.

COUNT NINE (INS FOIA REQUEST)

164. Al Fayed and Punch repeat and reallege the allegations contained in paragraphs 1 through 68 above, inclusive.

165. By letters dated July 27, 2000, Al Fayed and Punch, through counsel, submitted a FOIA request to the INS's headquarters in Washington, D.C. and office in New York City for disclosure of all information pertaining to twenty categories of names and events related to the August 31, 1997, deaths of Princess Diana, Dodi Al Fayed and Henri Paul. See Exhibit "1". The request additionally sought expedited processing and a fee waiver.

166. By letter dated August 3, 2000, the INS's New York office indicated that it had searched for records that relate to the request, had determined that if any records existed they would be maintained under the jurisdiction of INS headquarters and referred the request to headquarters. The INS New York City office assigned Al Fayed and Punch's request number NYC2000007354. Upon information and beliet no search for responsive reGords was ever conducted.

167. No further response has been received by the INS.

168. The INS has failed to comply with the requisite statutory periods that govern compliance under the FOIA. Therefore, the INS has wrongfully withheld documents from Al Fayed and Punch.

169. Al Fayed and Punch are not required to exhaust administrative remedies as the INS has not issued a formal determination regarding the documents.

170. Al Fayed and Punch have a legal right under the FOIA to be granted expedited processing, a fee waiver, and to obtain the information they seek, and there is no legal basis for the denial by the INS of said right.

COUNT TEN (USSS FOIA REQUEST)

171. Al Fayed and Punch repeat and reallege the allegations contained in paragraphs 1 through 68 above, inclusive.

172. By letter dated July 31, 2000, Al Fayed and Punch, through counsel, submitted a
FOIA request for disclosure of all information pertaining to twenty categories of names
and events related to the August 31, 1997, deaths of Princess Diana, Dodi Al Fayed and
Henri Paul. See Exhibit "1". The request additionally sought expedited processing and a
fee waiver.

173. By letters dated August 25, 2000, the USSS assigned the FOIA requests file numbers 2000515 through 2000521 and 2000525.

174. No other relevant response has been received by the USSS.

175. The USSS has failed to comply with the requisite statutory periods that govern compliance under the FOIA. Therefore, the USSS has wrongfully withheld documents from Al Fayed and Punch.

176. Al Fayed and Punch are not required to exhaust administrative remedies as the US SS has not issued a formal determination regarding the documents.

177. Al Fayed and Punch have a legal right under the FOIA to be granted expedited processing, a fee waiver, and to obtain the information they seek, and there is no legal basis for the denial by the USSS of said right.

COUNT ELEVEN (APA - EXPEDITED PROCESSING)

178. Al Fayed and Punch repeat and reallege the allegations contained in paragraphs 1 through 68 above, inclusive.

179. Requests for expedited processing of all responsive records were submitted to each of the defendant agencies as permitted by statute and internal agency regulation.

180. The CIA, NSA, DoD, DOJ and DOS each denied the request. The DIA, FBI, EOUSA, INS and USSS have failed to timely respond.

181. Al Fayed and Punch have met the requisite requirements as set forth in the respective agency regulations to be entitled to expedited processing of their FOIA requests.

182. By denying Al Fayed and Punch's request for expedited processing, the CIA, NSA, DoD, DOJ and DOS have each violated their respective internal regulations.

183. The DIA, FBI, EOUSA, INS and USSS have failed to comply with the requisite statutory periods that govern compliance under their respective agency regulations. Therefore, these defendants have violated the requirements of their internal regulations.

184. Al Fayed and Punch are not required to exhaust administrative remedies with respect to a denial of a request for expedited processing, nor under circumstances where an agency has failed to issue a formal determination regarding the request.

185. Al Fayed and Punch have a legal right under the respective regulations of the agency defendants to be granted expedited processing, and there is no legal basis for the denial by the CIA, NSA, DIA, DoD, DOJ, DOS, FBI, EOUSA, INS and USSS of said right.

WHEREFORE, plaintiffs Mohammed al Fayed and Punch Limited pray that this Court:

(1) orders the CIA, NSA, DIA, DoD, DOJ, DOS, FBI, EOUSA, INS and USSS to disclose the requested records in their entireties and make copies promptly available to them;

(2) grant expedited processing, or otherwise expedite this action in every way pursuant to 28 U.S.C. § 1657 (a);

(3) award plaintiffs reasonable costs and attorney's fees as provided in 5 U.S.C. § 552 (a)(4)(E) and/or 28 U.S.C. § 2412 (d); and

(4) grant such other relief as the Court may deem just and proper.

Date: August 31, 2000

[Signature]
Mark S. Zaid, Esq.
D.C. Bar #440532
Lobel, Novins & Lamont
1275 K Street, N.W.
Suite 770
Washington, D.C. 20005
(202) 371-6626

Counsel for Plaintiffs

--------------------------------------------------------------------------------

[Exhibit 1]

26 July 2000

REQUESTS SUBMITTED PURSUANT TO THE
FREEDOM OF INFORMATION ACT
BY MOHAMED AL FAYED AND PUNCH MAGAZINE

Request No. 1

All records relating to Diana Frances Spencer, Princess of Wales (DOB: July 1, 1961; British citizen), Emad "Dodi" Fayed (aka Imad Mohamed Fayed)(DOB: 1955; Egyptian citizen) and/or Henri Paul (DOB: July 3, 1956; French citizen) all of whom were killed in Paris, France on August 31, 1997. The deaths of these three individuals cannot be in dispute.
Request No. 2:

All records relating to the August 31, 1997, deaths of Emad "Dodi" Fayed (aka Imad Mohamed Fayed), Henri Paul and/or Diana Frances Spencer, Princess of Wales, that occurred in Paris, France.
Request No. 3:

All records relating to the inquiry conducted by investigating French Judge (Premier Juge d'instruction) Hervé Stéphan regarding the August 31, 1997, deaths of Emad "Dodi" Fayed (aka Imad Mohamed Fayed), Henri Paul and/or Diana Frances Spencer, Princess of Wales, that occurred in Paris, France.
Request No. 4:

All records relating to surveillance and/or intelligence gathering activities directed at or originating from Emad "Dodi" Fayed (aka Imad Mohamed Fayed), Diana Frances Spencer, Princess of Wales and/or Henri Paul.
Request No. 5:

All records relating to Mohamed Al Fayed, a resident of London, England and the father of Emad "Dodi" Fayed (aka Imad Mohamed Fayed). An Authorization and Privacy Waiver is enclosed as Exhibit "1A". The original is maintained in my possession.
Request No. 6:

All records relating to Trevor Rees-Jones (DOB: 1968; British citized including, but not limited to, his book "The Bodyguard's Story", and the book's ghost writer Moira Johnston.
Request No. 7:

All records relating to an effort in 1997-98 to sell classified or unclassified records, allegedly created by or from the possession of the CIA, pertaining to the deaths of Emad "Dodi" Fayed (aka Imad Mohamed Fayed) and Diana Frances Spencer, Princess of Wales.
Request No. 8:

All records relating to Keith Fleer, an entertainment lawyer in Los Angeles, California, and the effort to sell classified or unclassified records, allegedly created by or from the possession of the CIA, pertaining to the deaths of Emad "Dodi" Fayed (aka Imad Mohamed Fayed) and Diana Frances Spencer, Princess of Wales.
Request No. 9:

All records relating to Karl F. Koecher, a former Czech spy who was arrested, charged, and subsequently exchanged in 1985, by the United States for Soviet dissident Anatoly Shcharansky, and the effort to sell classified or unclassified records, allegedly created by or from the possession of the CIA, pertaining to the deaths of Emad "Dodi" Fayed (aka Imad Mohamed Fayed) and Diana Frances Spencer, Princess of Wales.
Request No. 10:

All records relating to Oswald LeWinter (aka George Mearah) (DOB: approximately 1930; United States citizen) including, but not limited to, his effort to sell classified or unclassified records, allegedly created by or from the possession of the CIA, pertaining to the deaths of Emad "Dodi" Fayed (aka Imad Mohamed Fayed) and Diana Frances Spencer, Princess of Wales. For your information, Mr. LeWinter has been tied to events involving the October Surprise and Iran-Contra scandals and the bombing of Pan Am Flight 103.
Request No. 11:

All records relating to Ricardo Shapp, and the effort to sell classified or unclassified records, allegedly created by or from the possession of the CIA, pertaining to the deaths of Emad "Dodi" Fayed (aka Imad Mohamed Fayed) and Diana Frances Spencer, Princess of Wales.
Request No. 12:

All records relating to George Williamson, a U.S. reporter, and the effort to sell classified or unclassified records, allegedly created by or from the possession of the CIA, pertaining to the deaths of Emad "Dodi" Fayed (aka Imad Mohamed Fayed) and Diana Frances Spencer, Princess of Wales.
Request No. 13:

All records relating to Pat McMillan (aka MacMillan), allegedly a former CIA agent, and the effort to sell classified or unclassified records, allegedly created by or from the possession of the CIA, pertaining to the deaths of Emad "Dodi" Fayed (aka Imad Mohamed Fayed) and Diana Frances Spencer, Princess of Wales.
Request No. 14:

All records relating to Jacques Pettier, an individual believed to reside at 8 Rue du Congres, Asniere-Paris, France.
Request No. 15:

All records relating to Richard John Charles Tomlinson, who was employed by the British intelligence agency MI6 between September 1991 and April 1995. An Authorization and Privacy Waiver is enclosed as Exhibit "1B". The original is maintained in my possession.
Request No. 16:

All records relating to the detention by U.S. govemment officials of Richard John Charles Tomlinson, who was employed by the British intelligence agency MI6 between September 1991 and April 1995, at John F. Kennedy International Airport after arriving on a Swiss Air flight on or about August 30, 1998. An Authorization and Privacy Waiver is enclosed. The original is maintained in my possession.
Request No. 17:

All records relating to David Shayler, but only to the extent the records pertain to Diana Frances Spencer, Princess of Wales, Emad "Dodi" Fayed (aka Imad Mohamed Fayed) and/or Henri Paul, all of whom were killed in Paris, France on August 31, 1997.
Request No. 18:

All records pertaining to requests received by intermediaries acting on behalf of Mohamed al-Fayed including, but not limited to, former Senator George Mitchell. This request pertains, but is not limited to, Senator Mitchell's letters to the CIA dated September 2 and 15, 1999, and DCI George Tenet's response dated September 30, 1999; Senator Mitchell's letter to Robert S. Tyrer, Chief of Staff, Office of the Secretary of Defense, dated September 17, 1999, and Mr. Tyrer's response dated October 4, 1999; and Secretary of Defense William Cohen's letter to Senator Mitchell dated April 28, 1999.
Request No. 19:

All records pertaining to Mohamed al-Fayed's efforts to obtain records or information relating to the death of his son Emad "Dodi" Fayed (aka Imad Mohamed Fayed) and Diana Frances Spencer, Princess of Wales. In responding to this request, you may exclude those records that were publicly filed as part of the legal proceedings in In re Application of Mohamed Al Fayed, Misc. No. 99-43 (D.D.C.); In re Application of Mohamed Al Fayed, Misc. No. 99-35 (D.Md.); In re Application of Mohamed Al Fayed, Appeal No. 99-1268 (4th Cir.); Mohamed Al Fayed v. Keith Fleer et al., Case No. BC 213751 (Sup. Ct. Los Angeles, Calif); Mohamed Al Fayed v. Keith Fleer et al., Case No. B137378 (Ct. App. 2nd Div. Calif ), except to the extent internal notations or comments have been added.
Request No. 20:

All records pertaining to the review of information provided by the Defense Intelligence Agency and the National Security Agency, pertaining to Emad "Dodi" Fayed (aka Imad Mohamed Fayed), Henri Paul and/or Diana Frances Spencer, Princess of Wales, including that which was deemed responsive to Mohamed Al-Fayed's FOIA requests, by any government officials including, but not limited to, Robert S. Tyrer, Chief of Staff, Office of the Secretary of Defense.

--------------------------------------------------------------------------------

[Exhibit 2]

KEITH G. FLEER
Loeb & Loeb LLP
Suite 1800, 1000 Wilshlre Boulevard
Los Angeles, Califorriia. 90017-2475
(Los Angeles County)
Telephone: 213-688-3400
Facsimile: 213-688-3460
Email: kfleer@loeb.com
Web-Site: http://www.loeb.com

Firm Listing

POSITION: Member

ADMITTED: 1967, District of Columbia; 1968, New York, 1976, California

LAW-SCHOOL: Washington College of Law of American University (J.D., 1967)

COLLEGE: American University (B.A., 1964)

TEXT: Omicron Delta Kappa (President) Business Editor, American University Law
Review. Member, National Moot Court Team. Recipient, Bruce Hughes Award and
Alumni Award, Outstanding Leadership and Scholarship. Co-Chair, 1991-1992 and
Member, 1983- , UCLA Entertainment Symposium Advisory Committee. Adjunct
Professor, University of Southern California Law Center, 1996. (Century City Office)

MEMBER: American Bar Association; Los Angeles Copyright Society (President, 1989); American Film Marketing Association (Member, Seminar Planning Committee).

BORN: February 28, 1943, New York, N.Y.

______________________________________

OSWALD LE WINTER

Known aliases:

George Mearah
Abrahim Razin
John Fishmah
Oscar Winter
Razin Le Winter
I. Semit
Thought to have born George Mearah

Date of Birih: 4 February 1931
Place of Birth: La Quenta, California

Last known US. address: 31900 Manherim Lane, La Quinto, California 92253

Additional information that may help facilitate searches:

In November 1997, he represented himself as a former CIA employee describing himself to the CIA as a Counter-Intelligence Director;
In 1995, he allegedly stood trial in Germany on weapons transfer changes anid was found guilty;
In 1991, he allegedly passed information to the BBC of CIA involvement in the death of the late Prime Minister Aldo Moro of Italy;
In 1990, he allegedly attended the World Jewish Conference in East Berlin, East Germany, and produced a card describing himself as a former CIA agent;
In 1989, he was allegedly convicted in Frankfurt, Germany of impersonation of a former CIA officer;
In 1984, he was allegedly arrested by the German police for drug trafficking.
In 1983, he allegedly represented himself as a Professor of Psychology at the University of Maryland;
In 1971, he allegredly obtained false credit by producing a forged New York Police Department badge;
He had himself listed in Who's Who in East Germany as a CIA agent.

--------------------------------------------------------------------------------

Transcription and HTML by Cryptome.

--------------------------------------------------------------------------------

[This is the court docket for an earlier proceeding.]

---------------------------------------------------------------------------

PACER Service Center

Transaction Receipt

09/01/2000 12:33:23
---------------------------------------------------------------------------

Docket as of April 19, 2000 8:25 pm Page 1

Proceedings include all events.
1:99ms43 In re: AL FAYED

APPEAL

APPEAL

U.S. District Court

USDC District of Columbia (Washington)

CIVIL DOCKET FOR CASE #: 99-MS-43

In re: AL FAYED Filed: 01/29/99
Assigned to: Judge Henry H. Kennedy
Demand: $0,000 Nature of Suit: 0
Lead Docket: None Jurisdiction: unknown
Dkt# in other court: None

Cause: Motion for Production of Documents & Continued Deposition
Case type: 1. miscellaneous

MOHAMED AL FAYED

In re:

-------------------------

CENTRAL INTELLIGENCE AGENCY Andrea M. Sharrin

Non Party FTS 616-8268

Room 943

[COR LD NTC gvt]

U.S. DEPARTMENT OF JUSTICE

Civil Division

901 E Street, NW

P.O. Box 883

Washington, DC 20530

AREA CODE (202)

DEPARTMENT OF INTELLIGENCE Andrea M. Sharrin
AGENCY (See above)

Non Party [COR LD NTC gvt]

-------------------------

MOHAMED AL FAYED Terrence O'Donnell

movant FTS 434-5000

202-434-5029 FAX

[COR LD NTC ret]

WILLIAMS & CONNOLLY

Edward Bennett Williams

Building

725 12th Street, NW

Washington, DC 20005

AREA CODE (202)

Docket as of April 19, 2000 8:25 pm Page 2

Proceedings include all events.
1:99ms43 In re: AL FAYED

APPEAL

Docket as of April 19, 2000 8:25 pm Page 3

Proceedings include all events.
1:99ms43 In re: AL FAYED

APPEAL
1/29/99 1 APPLICATION (EXPARTE) by movant MOHAMED AL FAYED for

order directing issuance of subpoenas pursuant to 28 USC

1782; exhibits (3) (bcs) [Entry date 02/02/99]

2/5/99 2 ORDER by Judge Henry H. Kennedy : granting motion for

order directing issuance of subpoenas pursuant to 28 USC

1782 [1-1] by MOHAMED AL FAYED (N) (dcn)

3/31/99 3 MOTION filed by movant MOHAMED AL FAYED to compel agencies

to comply with subpoenas issued to DOD and CIA ; exhibits

(4) (tb) [Entry date 04/01/99]

4/19/99 4 MOTION filed by Non Party CIA, Non Party DEPT/INTELLIGENCE

to extend time to 4/29/99 to respond to plaintiff's motion

to compel and order (adc) [Entry date 04/20/99]

5/13/99 5 MOTION filed by Non Party CIA to quash the subpoena;

exhibits (16) (tb) [Entry date 05/14/99]

5/26/99 6 REPLY by movant MOHAMED AL FAYED in support of motion to

compel agencies to comply with subpoenas issued to DOD and

CIA [3-1] by MOHAMED AL FAYED; exhibits (2) (tb)

[Entry date 05/27/99]

5/26/99 7 RESPONSE by movant MOHAMED AL FAYED in opposition to

motion to quash the subpoena [5-1] by CIA . (tb)

[Entry date 05/27/99]

6/8/99 8 NOTICE OF FILING RE: declaration of Georges Kiejman by

movant MOHAMED AL FAYED; attachment (tb)

[Entry date 06/09/99]

6/18/99 9 REPLY by Non Party CIA in support of to motion to quash the

subpoena [5-1] (jf) [Entry date 06/21/99]

9/2/99 10 SUPPLEMENTAL MEMORANDUM by movant MOHAMED AL FAYED in

support of motion to compel agencies to comply with

subpoenas issued to DOD and CIA [3-1] by MOHAMED AL FAYED;

Exhibit. (lkn) [Entry date 09/08/99]

9/22/99 11 MOTION filed by Non Party CIA to strike supplemental

memorandum [10-1], or for leave to file response and

notice of recent events (tb)

10/6/99 12 MEMORANDUM by In re: MOHAMED AL FAYED in opposition to

motion to strike supplemental memorandum [10-1] [11-1] by

CIA; exhibits (2) (tb) [Entry date 10/07/99]

2/24/00 13 MOTION filed by In re: MOHAMED AL FAYED for status

conference hearing ; exhibit (1) (bjsp)

[Entry date 02/25/00]

Docket as of April 19, 2000 8:25 pm Page 4

Proceedings include all events.
1:99ms43 In re: AL FAYED

APPEAL
3/29/00 14 ORDER by Judge Henry H. Kennedy : granting motion to

quash the subpoena [5-1] by CIA, denying motion to compel

agencies to comply with subpoenas issued to DOD and CIA

[3-1] by MOHAMED AL FAYED, vacating this Court's 2/5/99

order directing issuance of a subpoena to the CIA [2-1] (N)

(adc) [Entry date 03/30/00]

4/10/00 15 MEMORANDUM OF DECISION by Judge Henry H. Kennedy : (N)

(N) (dcn)

4/10/00 16 JUDGMENT by Judge Henry H. Kennedy; dismissing 99ms43 (dcn)

4/12/00 17 NOTICE OF APPEAL by movant MOHAMED AL FAYED from order

[14-1], entered on: 3/30/00 and judgment order [16-1],

entered on: 4/10/00. $5.00 filing fee paid and $100.00

docketing fee paid. Copies mailed to all parties. (tth)

[Entry date 04/13/00]

4/13/00 -- TRANSMITTED PRELIMINARY RECORD on appeal [17-1] by MOHAMED

AL FAYED to U.S. Court of Appeals (tth)

4/13/00 18 LETTER filed by Appellant Mohamed Al Fayed pursuant to

Federal Rule of Appellate Procedure 10(b). (tth)

[Entry date 04/18/00]

4/18/00 -- USCA # 00-5150 assigned for appeal [17-1] by MOHAMED AL

FAYED (tth) [Entry date 04/19/00]

[END OF DOCKET: 1:99ms43]

---------------------------------------------------------------------------

--------------------------------------------------------------------------------

[Court of Appeals docket.]

______________________________________________________

PACER Service Center
Transaction Receipt

09/01/2000 18:21:32
______________________________________________________

General Docket
US Court of Appeals for the DC Circuit

D.C. Circuit Court of Appeals

Court of Appeals Docket #: 00-5150 Filed: 4/17/00
Nsuit: 2890 Other Statutory Actions
In Re: Al Fayed v.
Appeal from: U.S. District Court

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Lower court information:

District: 0090-1 : 99ms00043 lead: 99ms00043

Trial Judge: Henry H. Kennedy, US District Judge

Date Filed: 1/29/99

Date order/judgment: 3/29/00

Date NOA filed: 4/12/00
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Fee status: paid

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Prior cases:

None
Current cases:

None

Docket as of August 26, 2000 0:36 am Page 1

00-5150 In Re: Al Fayed v.

MOHAMED AL FAYED David E. Kendall

Appellant FAX 202-434-5792

202-434-5145

[COR LD NTC ret]

Paul C. Rauser

[COR ret]

Williams & Connolly

725 12th Street, NW

Washington, DC 20005

202-434-5000

v.

CENTRAL INTELLIGENCE AGENCY Wilma Antoinette Lewis, U.S.

Appellee Attorney

202-514-6600

[COR gvt]

U.S. Attorney's Office

(USA) Civil Appellate

555 4th Street, NW

Washington, DC 20001

202-514-7159

David William Ogden, Acting

Assistant Attorney General

202-514-3301

Room 9530

[COR gvt]

Mark B. Stern, Attorney

202-514-5089

Room 9135

[COR gvt]

H. Thomas Byron, III, Attorney

202-616-5367

Room 9106

[COR LD NTC gvt]

U.S. Department of Justice

(DOJ) Civil Division, Appellate

Staff

601 D Street, NW

Washington, DC 20530-0001

DEPARTMENT OF INTELLIGENCE Wilma Antoinette Lewis, U.S.
AGENCY Attorney

Appellee (See above)

[COR gvt]

David William Ogden, Acting

Assistant Attorney General

(See above)

[COR gvt]

Mark B. Stern, Attorney

(See above)

Docket as of August 26, 2000 0:36 am Page 2

00-5150 In Re: Al Fayed v.

[COR gvt]

H. Thomas Byron, III, Attorney

(See above)

[COR LD NTC gvt]

Docket as of August 26, 2000 0:36 am Page 3

00-5150 In Re: Al Fayed v.

Mohamed Al Fayed

Appellant

v.

Central Intelligence Agency; Department of Intelligence
Agency

Appellees

Docket as of August 26, 2000 0:36 am Page 4

00-5150 In Re: Al Fayed v.

4/17/00 CIVIL-US CASE docketed. Notice of Appeal filed by Appellant

Mohamed Al Fayed. [515211-1] (sha)

4/18/00 ENTRY OF APPEARANCE filed by Attorneys Paul C. Rauser

(application to be submitted), David E. Kendall for

Appellant Mohamed Al Fayed (Styled as "Representation

Statement" and received by the Court on 4/14/00 before case

opening). [511176-1]. (sha)

4/19/00 CLERK'S ORDER filed directing Appellant to file [511418-1]:

docketing statement; certificate of counsel; statement of

issues; lower court decision; any procedural motions;

deferred appendix notice due 5/19/00; any dispositive

motions due 6/5/00. Directing Appellee to file [511418-2]:

certificate of counsel; any procedural motions; appearance

form due 5/19/00; any dispositive motions due 6/5/00.

[Entry Date: 4/19/00] (sha)

4/20/00 ENTRY OF APPEARANCE filed by Attorney H. Thomas Byron for

Appellees' Dept Intelligence, and CIA [511980-1]. (jth)

4/20/00 ENTRY OF APPEARANCE filed by Attorney Mark B. Stern for

Appellees' Dept Intelligence, and CIA [511981-1]. (jth)

5/19/00 INITIAL SUBMISSIONS filed by Appellant Mohamed Al Fayed

[518422-1] : docketing statement; certificate of counsel;

statement of issues; lower court decision; deferred

appendix notice (Deferred Appendix needed = Y). (wmw)

5/19/00 ENTRY OF APPEARANCE filed by Attorney Paul C. Rauser for

Appellant Mohamed Al Fayed, David E. Kendall for Appellant

Mohamed Al Fayed [518432-1] . (wmw)

5/19/00 STIPULATION filed (5 copies) Regular Stand-By Pool

[518437-1], establishing the initial briefing schedule

[518437-2] : Appellant's brief due on 6/9/00; Appellant's

appendix due on 6/9/00; Appellee's brief due on 6/30/00;

Appellant's reply brief due on 7/10/00. (wmw)

5/23/00 ENTRY OF APPEARANCE filed by Attorney David E. Kendall for

Appellant Mohamed Al Fayed [518958-1] . (sha)

6/1/00 CLERK'S ORDER filed to schedule oral argument [520609-1]

before Judge Initials: SFW DBS JWR on 9/6/00 at 9:30 AM .

[Entry Date: 6/1/00] (cwc)

6/9/00 BRIEF filed by Appellant Mohamed Al Fayed [522561-1].

Copies: 15. Certificate of service date 6/9/00. (jth)

6/9/00 APPENDIX filed by Appellant Mohamed Al Fayed [522564-1].

Copies: 10. Certificate of service date 6/9/00. (jth)

Docket as of August 26, 2000 0:36 am Page 5

00-5150 In Re: Al Fayed v.

6/30/00 BRIEF filed by Appellee's CIA, Department of Intelligence

[527498-1]. Copies: 15. (Certificate of personal service

dated 6/30/00). (jth)

7/10/00 REPLY BRIEF filed by Appellant Mohamed Al Fayed [528376-1].

Copies: 15. (Certificate of personal service date 7/10/00).

(jth)

8/25/00 PER CURIAM ORDER filed to allocate oral argument times:

APET minutes- 10 ERES minutes- 10. [539182-1], One

counsel per side to argue. [539182-2] Oral argument

scheduled for 9/6/00, Form 72 notice of attorney arguing

case - [539182-3] due 9/1/00 for CIA, for Mohamed Al Fayed

. . Before Judges Williams, Sentelle, Rogers . [Entry

Date: 8/25/00] (lej)

Docket as of August 26, 2000 0:36 am Page 6

--------------------------------------------------------------------------------




RMN is an RA production.

Articles In This Thread

TEXT OF AL FAYED'S LAWSUIT Part One
Rayelan -- Saturday, 2-Sep-2000 15:57:02
TEXT OF AL FAYED'S LAWSUIT Part Two
Rayelan -- Saturday, 2-Sep-2000 16:00:56
TEXT OF AL FAYED'S LAWSUIT Part Three
Rayelan -- Saturday, 2-Sep-2000 16:02:27
Re: TEXT OF AL FAYED'S LAWSUIT Part Two
Noah -- Sunday, 3-Sep-2000 09:11:12
Rogue Agents Galore?
Patriotlad -- Sunday, 3-Sep-2000 11:11:11

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