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Vannoy, Elizabeth
From: Aufhauser, David
Sent: Thursday, April 25, 2002 7:16 PM
To: Vannoy, Elizabeth
Subject: FW: Relevant due dates

FW Updates m

print

Original Message
From: Hammerle, Barbara
Sent: Thursday, April 25, 2002 6:11 PM
To: Aufhauser, David; Wolfe, George; McGivern, Tom; Fox, William;
Sanders, Traci; Munk, Russell; Muench, Marilyn
Subject: FW: Relevant due dates

Sandra Schraibman just sent the attached chart showing deadlines in BIF, GRF, HLF and
Barakaat.

Original Message
From: Schraibman, Sandy (mailto:Sandy.Schraibman@usdoj.gov]
Sent: Thursday, April 25, 2002 6:08 PM
To: 'Barbara.Hammerle@do.treas.gov'
Subject: Relevant due dates

Barbara: Here is the corrected list of relevant due dates in the five cases. We need to
send out formal notice to Holy Land by tomorrow about reopening the record for
consideration of redesignation. For next week alone, we have:
* Monday - BIF to file its opposition to our classified evidence motion.
* Tuesday - We file our opposition to BIF's motion for discovery. (We are in the
process of drafting and revising that brief, but time is going to be very tight for review
of all these briefs.)
* Wednesday - Our motion to submit classified evidence due in Holy Land.
* Thursday - We file our reply brief in BIF on classified evidence.
* Friday - Our day of "rest."

Thanks for sending this around to everyone. Sandra

NCTA000205451
 RELEVANT DATES FOR TERRORISM CASES
AS OF APRIL 25, 2002

Global Relief Foundation ("GRF") (ND ILL.)

* March 27 - we filed our combined motion to dismiss and for summary judgment and opposition
to motion for preliminary injunction
* April 19 - GRF's PI reply filed
* May 7 - GRF's opposition to our motion to dismiss
* May 13 - Return to GRF of copies of hard drives seized per FISA warrant
* May 27 - GRF's opposition to our motion for summary judgment
* June 15- Return copies (CD-ROMS) of BIF's documents
* June 7 - Our reply re our motion to dismiss
* June 28- Our reply re our motion for summary judgment

Benevolence International Foundation (BIF) (ND ILL)

* April 18 - Our motion to submit classified evidence filed

* April 22 - Return of New Jersey documents to BIF
* April 29 - BIF's opposition to our classified evidence motion
* April 30 - Our opposition to BIF's motion to take discovery
* May 2 - Our reply on our classified evidence motion
* May 13 - Our opposition to BIF's motion for prelim, injunction and our dispositive motions
- Return to BIF copies of hard-drives seized per FISA warrant
* June 12 - BIF's reply on PI motion and opposition to our dispositive motions
* June 15 - Return date for copies of BIF's documents
* July 12 - Our reply brief due on our dispositive motions

Holy Land Foundation ("HLF") (DDC)

* April 5 - HLF filed its motion for preliminary injunction

* April 15 - We filing motion for 60 day extension to respond (HLF has agreed
to a 30 day extension)
* April 22 - Status conference before Judge Kessler (DDC)
* April 26 - Notice to HLF re reopening the record for redesignation (?)
* May 1 - Our motion to submit classified evidence
* May 8 - HLF's opposition to our classified evidence motion
* May 13 - Our reply on our classified evidence motion
* May 31 - Our opposition to HLF's prelim, injunction motion and our dispositive motions
* June 17 -HLF's reply on PI motion and opposition to our dispositive motions
* June 24 -Our reply brief due on our dispositive motions
* July 16-19 - Hearing on PI begins (Tentatively set for 3-day evidentiary hearing, but if judge
decides that a hearing is not necessary, then oral argument)

Global Services International, Inc. and Abdullahi Farah v. USA (D. Minn.)

* April 15 - Complaint filed

* April 18 - Complaint served on US Attorney's Office
* June 17 - Answer due

Aaran Money Wire Services, Inc. and Garad Nor, aka Garad Jama v. USA (D. Minn.)

* April 15 - Complaint filed

NCTA000205452
April 18 - Complaint served on US Attorney's Office
June 17 - Answer due

Original Message
From: Bloemendal, Katharine
Sent: Friday, April 12, 2002 5:09 PM
To: Schraibman, Sandy
Subject: Updates

Global Relief, Benevolence and Holyland are discussed on page 9 of the attached list.
Thanks so much for your help in updating this information. If you could get the updates to me
by Monday around 11 a.m. that would be great. Thanks so much for your help. Katherine

« File: WatchCases »

NCTA000205453
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US District Court Civil Docket

US District Court for the District of Minnesota
(Minneapolis)

0:02cv789

Aaran Money Wire, et al v, USA, et al

This case was retrieved from the court on Friday, March 26, 2004

Date Filed: 04/15/2002 Class Code: CLOSED

Assigned To: Chief Judge James M Rosenbaum Closed: Yes
Referred To: Magistrate Judge Franklin L Noel Statute: 05:702
Nature of suit: Other Civil Rights (440) Jury Demand: None
Cause: Administrative Procedure Act Demand Amount: $0
Lead Docket: None
Other Docket: None
Jurisdiction: U.S. Government Defendant

Litigants Attorneys
Aaran Money Wire Service, Inc PUIce J Foster
PLAINTIFF [COR LD NIC]
Fredrikson & Byron
200 S 6TH St Ste 4000
Minneapolis, MN 55402-1425
USA
612-492-7110
Fax:612-492-7077
Email: Dfoster@fredlaw.com

John William Lundquist

[COR LD NIC]
Fredrikson & Byron
200 S 6TH St Ste 4000
Minneapolis, MN 55402-1425
USA
612-492-7000

h1^s://courtlirik.lexisnexis.com/DocketDirect/ShowDocket.asp?Court=43&Docket=0%3A... 3/26/2004
 UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA

AARAN MONEY WIRE SERVICE, INC., et al., Civil No. 02-789 (JMR/FLN)

Plaintiffs,
v.

THE UNITED STATES of AMERICA, et al.,

Defendants,

and

GLOBAL SERVICES INTERNATIONAL, INC., et al., Civil No. 02-790

Plaintiffs,
v.

THE UNITED STATES OF AMERICA, et al.,

Defendants.

PLAINTIFFS' MEMORANDUM IN OPPOSITION

TO DEFENDANTS' MOTION TO DISMISS

(ORAL ARGUMENT REQUESTED)

INTRODUCTION

Defendants' motion is nothing more than a transparent attempt to hold themselves above

the law that applies to all other defendants in their position. Defendants violated Plaintiffs'

constitutional and statutory rights in a manner that is astonishingly blatant and unapologetic.

They then ignored Plaintiffs' pleas for relief for many months, while Plaintiffs suffered

extraordinary irreparable harm. They gave Plaintiffs no formal or informal hearing. They

disregarded Plaintiffs' offers to restructure their businesses. They ignored letters from Plaintiffs'

counsel, and even refused to return counsel's phone calls. When Plaintiffs realized it was