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FREEDOM’S FRONTIE R “ There is little value is ensurin g the survival of our
FREEDOM’S FRONTIE R “ There is little value is ensurin g the survival of our

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There is little value is ensuring the survival of our nation if our traditions do not survive with it.”‐John F. Kennedy

Mario Dell’Osso Wednesday December 14,2011

Mario Dell’Osso Wednesday December 14,2011
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September 11, 2011 stands as a moment in history where everything changed, the world was shocked as those two airplanes flew into the building and a fireball exploded. At that moment in history, life for both Americans and Canadians was going to change. Many people were shocked by the incidents, many felt vulnerable to the attacks. A small group of men armed with primitive weapons (box cutters) could bring down an entire nation and stop economic flow. When people feel vulnerable they turn to the government for protection. The government provides protection by enacting legislation, legislation which can and does encroach on people’s rights. The United States passed the US PATRIOT Act within a month of the attack (US Government Printing Office, 2001). This new act authorized law enforcement additional tools and authorities to disrupt the efforts of terrorists. The United States by virtue of this act and the establishment of the Department of Homeland Security have begun massive intrusions into people’s lives, where they were authorized to make intrusions into the people’s lives with reduced judicial oversight, for example, the reasons for authorizing the search warrants need not be disclosed if it could be detrimental to the investigations. Canada enacted similar legislation making it illegal to support terrorist organizations, commit and indictable offence in assistance to a terrorist, as well as arrest a person when a terrorist attack is imminent. The new legislation also amended the tracking of money and the transfer of it around the world. Important is that there were provisions to keep secret and confidential evidence away from public disclosure, especially since Canada is a net consumer of intelligence given out foreign intelligence capacity is limited by virtue of the CSIS Act. The issue looking forward will become what limits we place on rights and freedoms in the name of security and the pursuit of disrupting terrorism and those who support them. The solution to this issue is not to give up freedom in the pursuit of security but to adhere to the rule of law and the principles of fundamental justice as guaranteed in the Charter of Rights and Freedoms.

Canada has always been a champion for civil rights and freedoms. Canada being founded largely on common law has always at its core the principal of Habeas corpus which is Latin for “you may have the body” (British Broadcoasting Corporation, 2005) , this was an attempt by legislators to make the state accountable for the body and prevent against unlawful detention. Following World War II, John Peters Humphrey, a Canadian legal scholar drafted what would become the Universal Declaration of Human Rights, what was referred to as the “international Magna Carta of mankind” (Kaplan & Neilson). In Canada, we codified various rights in the Canadian Bill Rights passed by John Diefenbaker’s government on August 10, 1960 and applied to all matters between citizens and the federal government (Magnet , 2001). On April 17, 1982 Canada severed all official links to the British courts by enacting the Canadian Constitution Act of 1982 which included the famous Charter of Rights and Freedoms, which included matters within the province as well as the division of powers between the province and the federal government (Magnet , 2001). In doing so, the Charter of Rights and freedoms became the supreme law of Canada,

“52. (1) The Constitution of Canada is the supreme law of Canada and any law that is inconsistent with the provisions of the Constitution is, to the extent of the inconsistency, of no force or effect.”

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This required the government to observe and defend the principles enshrined in the Charter. The Charter empowered the courts to be the executors of freedoms and rights, empowering them to act on anyone’s rights who have been infringed.

24 (1) Anyone whose rights or freedoms, as guaranteed by this Charter, have been infringed or denied may apply to a court of competent jurisdiction to obtain such remedy as the court considers appropriate and just in the circumstances.

This allowed for the balancing of the state’s power (the executive branch) against the courts (the judicial branch). To this day a person may apply to the federal court for habeas corpus ad subjiciendum

(essentially an arrest warrant) in relation to any member of the Canadian Forces serving abroad, and in

Ontario you may petition the court for habeas corpus or any of the other common law prerogative writs.

The most important and often contested section of the Charter is section 7 which guarantees the right to life, liberty and security of person except within the principles of fundamental justice. As such has been the subject of judicial proceedings in various manners, for example people claiming refugee status argued their denial to a full hearing violated their rights (Singh v. Canada (Singh v. Minister of Employment and Immigration); basically allowing everyone who reaches Canadian soil to make a refugee claim. More recently, the cases of Manickavasagam Suresh whereby he was found to be a member of a terrorist organization but the court held that a person could not be sent to a country that they could be tortured Suresh v. Canada (Minister of Citizenship and Immigration). The principles of fundamental justice have long been held to be somewhat vague; courts have held that generally these principles rely on four major factors:

“This basic principle has a number of facets. It comprises the right to a hearing. It requires that the hearing be before an independent and impartial magistrate. It demands a decision by the magistrate on the facts and the law. And it entails the right to know the case put against one, and the right to answer that case. Precisely how these requirements are met will vary with the context. But for s. 7 to be satisfied, each of them must be met in substance.” (Charkaoui v. Canada (Citizenship and Immigration), 2007)

The Charter of Rights and Freedoms herein referred to as the Charter as it provided with various rights but it also acknowledge the need for what some call flexible rights. This is contemplated in the first section of the Charter which sets out that the Charter is applicable within the reasonable limits imposed on a free and open society where the supremacy of the rule of law prevails. It emphasises the importance of the rule of law, the laws enacted by the people through their Member of Parliament. It also maintained the need to adhere to the rule of law and that people be dealt with in all matters in accordance with the laws.

The courts have long held that rights and freedoms are not fixed, they are not guaranteed regardless of the use of them, nor can the government use the premise of the rule of law to degrade them. This was affirmed by the Supreme Court of Canada in the matter of Her Majesty the Queen (in right of Canada) versus David Edwin Oakes in 1985. In this case David Oakes was charged and convicted of possession of a prohibited substance under the Narcotics Control Act. Under the

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Narcotics Control Act if you were found in possession of a controlled substance you were deemed to also be guilty of trafficking the substance unless you could prove otherwise on a balance of probabilities, that it was more unlikely than it is. The Supreme Court of Canada held that such a provision was in violation of the David Oakes rights, as under section 11 of the Charter he is presumed to be innocent until proven guilty beyond a reasonable doubt. The reverse onus provision was struck out by the court as unconstitutional. What is most important is that the court established what has come to be known as the Oakes Test. The Oakes Test is the measure by which court determines if an impinged law is consistent with the Charter and its various previsions. The Supreme Court set forth essentially three grounds that the government must establish for a law to be deemed to reasonable in terms of its infringement of Charter rights, thus setting the limits on law and on the application of the rights guaranteed by the Charter. The Supreme Court held that legislation must have an objective to deter a specific action, secondly that the legislation and the action are reasonably and logically connected, and that the level of infringement be proportional to that of the action which the legislation seeks to eliminate (Dickson, 1985). In short, the Court held the actions of legislation can be no more intrusive than necessary.

Canada has long dealt with terrorists via various mechanisms, some criminal others quasi‐ judicial. Canada’s various immigration laws have always contained a provision to deal with non‐ citizens (foreign nationals) by way of a Security Certificate issued by a Minister of the Crown; security certificates have been in place since 1978 (Government of Canada, 2009). These security certificates were used as the principal means of removing people from Canada who were a risk to the Canadian public and through their association to terrorists groups or their terrorist actions abroad. The certificates first came under the scrutiny of the court in 2002, when Manickavasagam Suresh argued that he should not be subject to deportation given that if he returned to Sri Lanka he would be subject to torture. Suresh advanced various arguments the first being that the term “terrorism” was too vague to be of any meaning and could encompass a number of things; the Supreme Court dismissed this argument. The applicant further argued that his freedom of association was impugned by the decision of the Minister, the Supreme Court held that:

“Expression taking the form of violence or terror, or directed towards violence or terror, is unlikely to find shelter under the Charter. Provided that the Minister exercises her discretion in accordance with the Act, the guarantees of free expression and free association are not violated.”[Emphasis added]

The applicant then advanced that he would be subject to deportation if returned to Sri Lanka, the Supreme Court took a firm stance, and stating that in accordance with Canada’s international obligations it would be unlawful to deport a person to a country where they would experience torture, a principle held even when extraditing someone:

“While this Court has never directly addressed the issue of whether deportation to torture would be inconsistent with fundamental justice, we have indicated on several occasions that extraditing a person to face torture would be inconsistent with fundamental justice. As we mentioned above, in Schmidt, supra, La Forest J. noted that s. 7 is concerned not only with the immediate consequences of an extradition order but also with “the manner in which the foreign state will deal with the fugitive on surrender, whether that course of conduct is justifiable or not under the law of that country” (p. 522). La Forest J. went on to specifically

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identify the possibility that the requesting country might torture the accused and then to state that “[s]ituations falling far short of this may well arise where the nature of the criminal procedures or penalties in a foreign country sufficiently shocks the conscience as to make a decision to surrender a fugitive for trial there one that breaches the principles of fundamental justice enshrined in s. 7” [Emphasis added]

After dealing with the various issues the Supreme Court held that the decision by the Minister was unreasonable and remitted it for redetermination by the Minister in accordance with the principles of fundamental justice but held the legislations was constitutional, essentially demanding a higher level of procedural fairness.

The security certificate then came under further scrutiny by the Supreme Court of Canada in 2007, whereby Adil Charkaoui a Moroccan‐born permanent resident of Canada was named in a security certificate signed by the Minister in May of 2003. In the security certificate Mr. Charkaoui was suspected of being a sleeper agent of Al‐Queda as the subject had admits to having contact with many known terrorists and to having visited Pakistan for Islamic education, including learning about the Koran, Islamic culture and practices. Mr. Charkaoui has never admitted to being a terrorist, however he did not admit to himself being a terrorist and the CSIS agent testifying was unable to say he was (Charkaoui (Re), 2003). Mr. Charkaoui fought a number of times to the Federal Court of Appeal seeking he be released.

The Supreme Court of Canada finally decided to hear his case in 2008. The applicant advanced one major argument, that being that the nature of security issues and the process that followed failed to adhere to the principles of fundamental justice. The Supreme Court held that the information available to a Federal Court judge was limited due to the need to keep the sources and means of such information secret as it was given in confidence. The major issue with the process was that the subject of a security certificate was not given the full case against him and therefore could not establish the bar that must be met. The Supreme Court ruled that this approach was unconstitutional and struck down the legislation, but held its decision for one year to allow parliament to reconfigure the legislation in accordance with the principles of fundamental justice.

The new legislation, enacted on October 22 of 2007 requires that after the minister had issued the security certificate is then provided to a security cleared judge of the Federal Court who will rule on its validity (Government of Canada, 2009). The case against the subject of the security certificate will then be given to the subject in a declassified version and the subject will be provided a lawyer (Special Advocate) who is also security cleared. This new approach has yet to be challenged at the Supreme Court, however, given the contents of the Charkaoui decision seems to adhere to the principles of fundamental justice, but only time will tell.

Turning now to the case of Mohammad Momin Khawaja a convicted terrorist, the first person prosecuted and convicted under Canada’s new Anti‐Terrorism legislation. He was specifically, was convicted of supporting a terrorist organization by providing monetary support, explosive material, amongst other terrorist activities under the various provisions of the Anti‐Terrorism legislation. The case was then appealed by the Attorney General to the Ontario Court of Appeals who upheld the decision (R. v. Khawaja, 2010). The Court of Appeal took a firm stance against the terrorism and

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increased the sentence to a term of life imprisonment to ensure the act is denounced and prevented in the future (R. v. Khawaja, 2010).

The most recent and most important decision relating to terrorism and the balance between freedoms and combating terrorism lie in the Ontario Superior Court’s judge Christopher M. Speyer’s decision to not extradite Abdullah Ahmed Khadr to the United States of America to face charges in relation to trafficking weapons in Pakistan. The facts of the case are quite clear; Abdullah Ahmed Khadr was born in Canada in 1981. He moved to Pakistan with his father (Ahmed Khadr) who was later killed fighting Pakistani forces in 1997. In 2001, the family moved to Afghanistan moving back shortly thereafter (United States of America v. Khadr, 2011). In late 2001, Ahmed was asked by Osama Bin Laden to help procure weapons to provide the Taliban to fight the United States, Coalition Forces and the Northern Alliance. In turn, Ahmed asked his son Abdullah to acquire weapons. Over a six month period in 2003, Abdullah trafficked approximately $20,000 in weapons which were given to those fighting the Northern Alliance and Coalition Forces (Hughes, 2005). Abdullah continued to sell weapons up until October 2004, making money and continuing after his father’s death (in October 2003) (Hughes, 2005).

Acting on a $500,000 bounty offered by the United States the Pakistani Inter‐Services Intelligence (ISI) captured Abdullah on the 15 of October 2004 in Islamabad, Pakistan (United States of America v. Khadr, 2011). Professor Javaid Rehman a professor of law in London, England testified that Pakistan was known to use torture and abuse to illicit information. The application’s judge held that while he accepted that Abdullah had been abused but found that his testimony was unreliable and thus did not accept that he had been tortured (The Attorney General of Canada v. Khadr, 2010). On October 19, 2011, American government officials notified CSIS officials of the arrest, amid media reports that a Canadian had been captured, however, they noted that Canadians had to wait to provide consular assistance until the “intelligence played out” (The Attorney General of Canada v. Khadr, 2010). It is important to note that the right of a foreign national imprisoned or detained in a foreign country has the right to have their country of citizenship notified under the Vienna Convention on Consular Relations. Under the supervision of the ISI, Canadian diplomatic officials were first granted consular access to Abdullah on January 12, 2005. It is important to remember that Abdullah during his detention was held in a secret jail and not afforded access to the Pakistani courts and has his detention verified, nor was his detention made public. The United States attempted to have him “renditioned” to the United States, however, Canadians didn’t agree, and thus the Pakistani government would not allow it, without Canada’s concurrence (The Attorney General of Canada v. Khadr, 2010). On December 1, 2005 Abdullah was repatriated to Canada where he gave a legal statement, his statement voluntarily and was afforded the legal rights guaranteed by the Charter.

Abdullah Khadr was arrested on December 16, 2005 for Extradition to the United States and was denied bail and held in detention until the hearing of his application to stay proceedings under section 24(1) of the Charter. This is an important case, in the discussion regarding the confronts of terrorism as it made clear the position of the court in relation to the use of torture to obtain evidence and the infringements on rights in the pursuit of security. The judge felt that the United States had not directly induced any malfeasance, however, by issuing the $500,000 bounty and

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denying or impeding Canadian counsellor access amounted to a deprivation of the rights of Abdullah Khadr (The Attorney General of Canada v. Khadr, 2010). As such, the judge ordered a stay of the extradition hearing as a manner to discourage any future malfeasance. Stating that,

“I recognize that the collection of reliable intelligence is of the highest importance in protecting and securing a nation from the dangers of terrorism. It must also be recognized that there will always be a tension, especially in troubled times, in the balancing of intelligence and security issues with cherished democratic values, such as the rule of law and protection from human rights violations. In civilized democracies, the rule of law must prevail over intelligence objectives. In this case, the sum of the human rights violations suffered by Khadr is both shocking and unjustifiable.”[Emphasis added]

Effectively ending the United States of America’s ability to prosecute Abdullah Khadr’s prosecution in the United States, justice Speyer did suggest that Abdullah Khadr is still liable to prosecution for his acts under Canada’s immigration law, as the RCMP’s statement obtained upon his return is legal.

This decision was further appealed by the Attorney General of Canada on behalf of the United States of America to the Ontario Court of Appeals. The court upheld the decision of the lower court holding that the judge made no reviewable error in his decision, again holding that the Abdullah was liable to prosecution in Canada. The statement of Justice Robert J. Sharpe will likely be reiterated in coming years as this decision will stand in history as the decision the judicial branch made regarding how the state can deal with terrorism, in accordance with the law.

The issues we face are important, it is important that Canadians and citizens around the world be mindful of the balance that need be struck between the state’s need to provide protection to its citizens. For example, when Canada introduced its Anti‐Terrorism legislation it included the provisions for Investigative hearings and detentions if need be (Queen's Press, 2011). Parliament limited the duration of these provisions to sunset (expire) on the fifteenth day of the sitting of Parliament after December 31, 2006. This legislation was not renewed by the government of the day; however, recently the Federal Government is set to introduce the provisions without a sunset clause (Taber, 2011). Under the previous legislation peace officers (police officers) could detain people when they suspected it was necessary on reasonable grounds to prevent a “terrorist activity”; which is defined in the act, but relatively broad as needed by the nature of terrorism.

Canada has seen the result of its intelligence operation in the name of security before; during the Cold War the Royal Canadian Mounted Police developed PROFUNC a plan to intern Communist Supporters. The results of the plan came to light when Canadians attempted to make entry into the United States and were denied entry based on a flag placed in the Canadian Police Information System (CPIC) (Beeby, 2000). The plan called for people to be detained at various sites throughout Canada before being processed and transferred to prisons (MacIntyre, 2010). The plan would be invoked on the basis of a “perceived security threat”. The list turned out to be largely people on the left of the political spectrum; they were put on a list of perceived threats because of their beliefs in a more progressive society, were there possibly some people who may have been communist, possibly. Statistically speaking if you cast a large enough net, include a large number of people on a list you are bound to find some terrorists.

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Looking at the United States of America’s approach to combating terrorism, they have taken a different approach to combating terrorism. Look at the recent killing of Anwar Al‐Awlaki and examine the legality of it. Al‐Awlaki as a suspected terrorist leader of al‐Qaida in the Arabian Peninsula

was killed by a bomb dropped from a predator in September 30, 2011 (msnbc.com news services, 2011). Thus Anwar Al‐Awlaki was assonated by the United States of America on the premise that he was never found guilty by a court of competent jurisdiction, nor was he called to stand trial on these charges. Remember that enshrined in the United States’ Constitution is the right to not “be deprived of life, liberty, or property, without due process of law” (5 th Amendment of the United States Constitution). The US Justice Department has not provided any legal justification for the killing nor has a court of competent jurisdiction of the US deemed it to be appropriate. The United States’ President relies on the Authorization of Use of Military Force signed into law by George Bush a week following the 9/11 attacks. This authorization gave the president unprecedented power,

“To use all necessary and appropriate force against those nations, organizations, or persons he determines planned, authorized, committed, or aided the terrorist attacks that occurred on September 11, 2001, or harboured such organizations or persons, in order to prevent any future acts of international terrorism against the United States by such nations, organizations or persons.”[Emphasis Added] (107th Congress, 2001)

It is clear that this authorization has given the executive branch, the government the unilateral authority to go after terrorists with as much force as deemed necessary. There was legal action sought before Al‐Awalaki was killed to end the US Government’s ability to carry out targeted assassinations on US citizens (Perez, 2010). The judge dismissed the appeal on the basis that he could not review the material as it involved the security of state secrets and thus lacked jurisdiction to act on the case. A glaring difference between the decision of the

Supreme Court of Canada in the case of Charkaoui v. Canada (Citizenship and Immigration), 2007 where the court ruled that the accused has the right to know the case against him, in accordance with the principles of fundamental justice. The difference between the cases is clear, that the Canadian judiciary will not tolerate the deprevation of rights in the persuit of security, where as the US judiciary will. In face, a US Justice Department spokesman, stated "recognized that a leader of a foreign terrorist organization who rejects our system of justice cannot enjoy the protection of our courts while plotting strikes against Americans." (Perez, 2010), drawing the limits on who the Constiution will apply to.

Based on the aforementioned information it seems obvious that in the 21 st century the solution to terrorism is not doing away with the Charter or empowering the executive branch to act without the oversight of the judicial branch, but rather dealing with those who seek to support or engage in terror should be dealt with in accordance with the rule of law and the principles of fundamental justice. For as was so eloquently stated by Justice Robert J. Sharp:

“the rule of law must prevail even in the face of the dreadful threat of terrorism. We must adhere to our democratic and legal values, even if that adherence serves in the short term to benefit those who oppose and seek to destroy those values. For if we do not, in the longer term, the enemies of democracy and the rule of law will have succeeded. They will have demonstrated that our faith in our legal order is unable to withstand their threats.”

If we should fail to observe the tenants of our democratic society and push back against freedom we do so at our own demise, for when is the line drawn. Terrorists thrive on the overreaction of the

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state in the hope that they can recruit more to their cause, in doing so calling upon more over reaction of the state, and more security regulations followed by more vicious attacks by terrorists. For in attempting to extinguish the problem of terrorism we will have created more terrorists and found ourselves in a downward spiral, left wondering where the line will be drawn and enough is enough. As it was once so famously said by John F. Kennedy, “there is little value is ensuring the survival of our nation if our traditions do not survive with it.”

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Works Cited

107th Congress. (2001, September 18). Authorization for Use of Military Force Joint Resolution. Retrieved December 1, 2011, from FindLaw:

http://news.findlaw.com/wp/docs/terrorism/sjres23.es.html

Her Majesty The Queen versus David Edwin Oakes, 17550 (Supreme Court of Canada 1985).

Charkaoui (Re), DES 3 03 (Federal Court July 15, 2003).

Charkaoui v. Canada (Citizenship and Immigration), SCR 350 (The Sumpreme Court of Canada Feburary 23, 2007).

R. v. Khawaja, ONCA 862 (Ontario Court of Appeal December 17, 2010).

The Attorney General of Canada v. Khadr, ONSC 4338 (Ontario Superior Court of Justice August 4, 2010).

United States of America v. Khadr, 358 (Ontario Court of Appeal May 6, 2011).

Beeby, D. (2000, January 24). RCMP Had Plan to Intern 'Subversives,' Proposal Called for Communists and Their Children to Be Rounded Up at the Outbreak of War. Globe and Mail , p. A2.

British Broadcoasting Corporation. (2005, March 9). A brief history of habeas corpus. Retrieved December 1, 2011, from BBC News:

http://news.bbc.co.uk/2/hi/ uk_news/magazine/4329839.stm

Government of Canada. (2009, June 5). Security certificates . Retrieved November 30, 2011, from Public Safety and Emergency Preparedness: http://www.publicsafety.gc.ca/prg/ns/seccert eng.aspx

Hughes, G. T. (2005, November 23). Affidavit of Gregory T. Hughes. Retrieved November 31, 2011, from http://en.wikisource.org/wiki/Affidavit_of_Gregory_T Hughes

Kaplan, W., & Neilson, L. (n.d.). John Peters Humphrey. Retrieved November 20, 2011, from The Canadian Encyclopedia:

http://www.thecanadianencyclopedia.co m/index.cfm?PgNm=TCE&ArticleId=A0003905

MacIntyre, L. (2010, October 15). CBC fifth estate. Retrieved December 6, 2011, from Enemies of the State: http://www.cbc.ca/fifth/2010 2011/enemiesofthestate/

Magnet , J. E. (2001). Constitutional Law of Canada. Edmonton: University of Ottawa.

msnbc.com news services. (2011, September 30). Born in US, Al Awlaki was his birth nation's sworn enemy. Retrieved December 7, 2011, from MSNBC TODAY News:

http://today.msnbc.msn.com/id/44730882/ns/world_news mideast_n_africa/#.TueGrLIk67t

Perez, E. (2010, Decemeber 8). Judge Dismisses TargetedKilling Suit. Retrieved November 30, 2011, from The Wall Street Journal:

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http://online.wsj.com/article/SB10001424052748703296604576005391675065166.html?mod=

googlenews_wsj

Queen's Press. (2011, November 14). Department of Justice . Retrieved December 1, 2011, from Criminal Code (R.S.C., 1985, c. C 46): http://laws lois.justice.gc.ca/eng/acts/C 46/

Taber, J. (2011, September 13). Tories disinclined to subject anti terror measures to sunset clause. Retrieved November 15, 2011, from The Globe and Mail:

http://www.theglobeandmail. com/news/politics/ottawa notebook/tories disinclined to subjectanti terrormeasures to sunsetclause/article2164415/

US Government Printing Office. (2001, October 26). Public Law 107 56 Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT ACT) Act of 2001 . Retrieved November 16, 2011, from US Government Printing Office:

http://www.gpo.gov/fdsys/pkg/PLAW 107publ56/contentdetail.html

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