User:Geo Swan/Guantanamo/Guantanamo captive's habeas corpus cases/Re Guantanamo Detainee Litigation Docs/Doc 703

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See User:Geo Swan/Stale drafts
 * MOTION to Amend/Correct Factual Returns by GEORGE W. BUSH, DONALD RUMSFELD, JAY HOOD, MIKE BUMGARNER, DONALD RUMSFELD, JAY HOOD, MICHAEL BUMGARNER (Attachments: # 1 Exhibit A, # 2 Text of Proposed Order)(Ahern, Paul)
 * On 10 October 2008 DoJ official Paul E. Ahern filed a "RESPONDENTS’ MOTION FOR LEAVE TO FILE AMENDED FACTUAL RETURN" in Civil Action No. 05-CV-1678 and 05-CV-2185 (TFH).
 * Ahern argued that the Department of Justice should be allowed to introduce new evidence to justify classifying captives as "enemy combatants", beyond that available, or used, in 2004. He argued that, for those petitions where the government had never filed a "factual return", the government was free to include new evidence when it filed the first returns in 2008, it should similarly be allowed to file amended factual returns for those captives who had already had a factual return filed prior to 2008.