Case: 10-5319 UNCLASSIFIED//FOR PUBLIC RELEASE Document: 1292955 Filed: 02/11/2011 Page: 106 SECRETNP!GFGRT! IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) ) ) ) ) ) ) ADNAN FARHAN ABD AL LATIF ALA'DINI (lSN 156) Petitioner, v. BARACK H. OBAMA, President of the United States, et aI., Respondents. Civil Action No. 04-cv-1254 (HHK) Exhibit 34 Petitioner's Declaration (May 10, 2009) PEanUT ,,,,rAPAn" T 'J..:J U LJ '-".I. .I. I I .1 "I .....,.1. ....., ..' 1 "I UNCLASSIFIED//FOR PUBLIC RELEASE JA 524 Case: 10-5319 UNCLASSIFIED//FOR PUBLIC RELEASE Document: 1292955 Filed: 02/11/2011 Page: 107 DECLARAnON OF ADNAN FARHAN ABO AL LATIF I, Adnan Farhan Abdul Latif, state that the following infonnation is based on my personal knowledge and is true and correct to the best of my infonnation, knowledge, and belief. If called as a witness in this matter, I could and would testify competently to the matters set forth in this declaration. 1. I W8S born in 1976 in Yemen. I have four sisters and two brothers. Before I left Yemen in the summer of 2001 t I worked with my father at his homo goods store. I am married and have one son, who was bom in 1999. At the date of this declaration, my son is ten years old. I have not seen him in nearly eight years. 2. In 1994, I was in a serious automobile accident. The car I was. in rolled over. My head, eyes, ears, and skull were seriously injured during the accident. I had a hemorrhage above my left eye, which caused blood' to concentrate in that area. My left eardrum was punctured. My skull was also broken during the accident. 3. Following the accident, the Government of Yemen paid for me to travel to Jordan to receive medical treabnent. I spent three months at the Islamic Jordanian Hospital in Amman, Jordan. Although my condition improved during my stay at th~ hospital, my doctor recommended that I return to the hospital six months after my discharge for further treatment 4. After I was released ftom the hospital, I returned to Yemen. I continued to suffer severe headaches, difficulty with my vision, and impaired hearing as a result of the automobile accident. These injuries, along with other medical problems UNCLASSIFIED//FOR PUBLIC RELEASE JA 525 Case: 10-5319 UNCLASSIFIED//FOR PUBLIC RELEASE Document: 1292955 Filed: 02/11/2011 Page: 108 such as arthritis, cause me severe pain to this day. I was unable to work because of these injuries. The government of Yemen designated me as a disabled person. 5. Medical care in Yemen is unreliable and not widely available. Many people leave the country to seek medical care, as I had done after my accident when I went to Jordan. However, my family did not have enough money to send me back to Jordan to complete my medical treatment, and the Oovemment of Yemen was unwilling to pay for a second trip. 6. The headaches and other pains associated with my injuries were difficult for me to bear, but I had no money to seek. further medical trcabnent. I began to look for charitable organizations that would pay for my medical treatment. I ask~ people at mosques, clinics, and other organizations if they knew of any organization that cou1d help me get the medical treatment I needed. I even had a letter from Abdullah bin Hussain at Abmar, the speaker of the Parliament. Urging people to help me find medical help. 7. Some people in the hospitals told me that I could find free medical help in Pakistan. Ibrahim, a Yemeni who I met in Jam-eiab Islam, one of the charitable organizations I approached in Yemen, told me that he was going to Pakistan soon and suggested that I find him there. He gave me his contact infonnation. He promised me that, if I went to Pakistan, he would take mc to a charitable medical clinic that would provide me with free medical care for my continuing medical problems. 8. In the summer of 200 1, I traveled to Pakistan and tried to find Ibrahim. I discovered that Ibrahim had gone to Kabul, Afghanistan, to administer charitable activities there. I followed him to Afghanistan. I took a bus to Quetta, Pakistan, and then 2 UNCLASSIFIED//FOR PUBLIC RELEASE JA 526 Case: 10-5319 UNCLASSIFIED//FOR PUBLIC RELEASE Document: 1292955 Filed: 02/11/2011 Page: 109 a taxi from QucUa into Afghanistan. 1 went to Kabul and located Ibrahim at an Islamic studies institute that he helped to run. He told me that he was too busy to accompany me) to Pakistan, but that he would soon return and go with me to the clinic in Pakistan. He offered to let me stay at the Islamic studies institute in Kabul until he was available to go with me to Pakistan. 9. I waited several weeb at the institute in Afghanistan, but Ibrahim never returned. After the United States began Bombing Afghanistan in late 200 1, some of the local people told me that I needed to leave Afghanistan for my safety. They told me that military forces from northern Mghanistan, which had a1lied with the United States, were rapidly advancing towards Kabul, and that they were likely to kill any Arabs they found. I took their advice and fled towards Pakistan. I traveled for many days and was arrested by Pakistani forces after I crossed the border into Pakistan. I was then transferred to the custody of the United States, who sent me to the prison at Guantanamo Bay. I was only in Afghanistan for a few months. 10. The United States Government says that my purpose in going to Afghanistan was to fight jihad. This a1lcgation is not truc. I went to Afghanistan for the first time in the summer of2001 to find Ibrahim, who had promised me that he could help me get free medical treatment in Pakistan for my cluonic painful medical conditions. I never told anyone that I went to Afghanistan to fight in a jihad. Given my medical conditions and disabilities, I was in no shape to be a fighter of any kind. . 11. I do not know if Ibrahim was or was not a member of Al Qaeda, though J am not aware of any facts that would indicate that this was the case. As far as I 3 UNCLASSIFIED//FOR PUBLIC RELEASE JA 527 Case: 10-5319 UNCLASSIFIED//FOR PUBLIC RELEASE Document: 1292955 Filed: 02/11/2011 Page: 110 am aware, his only activities in Afghanistan were to run charitable medical clinics and other charitable activities. 12. I have never received any weapons training, from the Taliban, at any training camp, or anywhere else. I have never participated in military fighting in Afghanistan or anywhere else. I never told anyone that I received weapons training, attended a training camp, or partiCipated in military fighting. As I have already stated, my only purpose in going to Afghanistan was to find the individual who promised me free medical care. 13. The United States says that I have many aliases. I use only two .names: My legal name is Adnan Farhan Abdul Latif, but I prefer to go by my religious name, Abdelrahman Abdulla Abdel JaIil. I have never used any other names or aliases. I have DO affiliati()n or connection with a1 Qaeda or the Taliban. My sole purpose in going to Afghanistan was to find the individual who said he could help me get medical treatment in Pakistan. 14. I have no connection to aJ Qacda and I have never served as any kind of bodyguard for anyone. I have never met Osama bin Laden. I have never seen Osama bin Laden. Until my interrogators asked me about Osama bin Laden, I had never even heard ofbim. ) S. I am not and have never been a member of any military organization. I have never participated in any kind of military hostilities against the United States, its allies, or any other nation or organization. I am not and never have been a member of the Taliban. I am not and never have been a member of al Qaeda. I am a disabled person 4 UNCLASSIFIED//FOR PUBLIC RELEASE JA 528 Case: 10-5319 UNCLASSIFIED//FOR PUBLIC RELEASE Document: 1292955 Filed: 02/11/2011 Page: 111 who was looldng for affordable medical treatment for very painful and long-lasting medical conditions. 16. I intend no harm to the United States, its people, or its aUies. If released, I will return to Yemen to be reunited with my family, and I will seek medical treatment for my cluonic conditions, which have only become mote painful and severe during my seven years in this prison. 5 UNCLASSIFIED//FOR PUBLIC RELEASE JA 529 Case: 10-5319 UNCLASSIFIED//FOR PUBLIC RELEASE Document: 1292955 Filed: 02/11/2011 ) " ...., j'~" . ,. .'. " " ,..,.~ .. ~ ,...'. \t " ~ . o } ~I ... ~i .' .... J f ... i 1 UNCLASSIFIED//FOR PUBLIC RELEASE JA 530 Page: 112