The excerpt below is taken from the amended complaint in the case Al Shimari v. CACI, filed in the US District Court for the Eastern District of Virginia in September 2008. The lawsuit has been brought by four Iraqi torture victims against private US-based contractor CACI International Inc., and CACI Premier Technology, Inc. It asserts that CACI participated directly and through a conspiracy in torture and other illegal conduct while it was providing interrogation services at the notorious Abu Ghraib prison in Iraq.

CACI argues that the case should be dismissed because the company was working for the US Government. A decision on whether to dismiss the case has still to be reached.

Read the complaint in full (pdf file)

The Torture of Suhail Najim Abdullah Al Shimarl

  • Mr. Al Shimari was imprisoned at the Abu Ghraib hard site for approximately two months after being arrested on or about November 7, 2003.
  • Mr. Al Shimari was subjected to electric shocks.
  • Mr. Al Shimari was struck with a baton-like instrument.
  • Mr. Al Shimari was beaten.
  • Mr. Al Shimari was deprived of food.
  • Mr. Al Shimari was deprived of sleep for extended periods of time.
  • Mr. Al Shimari was threatened with dogs.
  • Mr. Al Shimari was subjected to sensory deprivation and to extreme temperatures.
  • Mr. Al Shimari was stripped naked and kept naked in his cell.
  • Mr. Al Shimari was threatened with death.
  • Mr. Al Shimari was kept naked and forced to engage in physical activities to the point of exhaustion.
  • Mr. Al Shimari was forcibly shaved. 3
  • Mr. Al Shimari was kept in a cage.
  • Mr. Al Shimari was forced to watch as CACI and its co-conspirators choked another prisoner.
  • Mr. Al Shimari was released on or about March 27, 2008, without ever being charged with any crime.

The torture conspiracy

  • All of these harms were inflicted on Plaintiffs by groups of persons conspiring together to torture detainees kept at the Abu Ghraib hard site.
  • Among the conspirators were CACI employees Big Steve, DJ, Timothy Dugan. Reasonable discovery likely will establish that other CACI employees also participated in the ongoing conspiracy to torture Plaintiffs and other prisoners.
  • Sworn and unsworn testimony from military co-conspirators describe CACI employees Steven Stefanowicz and Daniel Johnson as among those interrogators who most frequently directed that detainees be tortured.
  • Big Steve, DJ and other corporate employees instigated, directed, participated in, aided and abetted conduct towards detainees that clearly violated the Geneva Conventions, the Army Field Manual, and the laws of the United States.
  • Reasonable discovery will establish that Big Steve, DJ, and other CACI employees and their co-conspirators attempted to avoid detection by treating certain detainees as “ghost detainees.” That term was the conspiracy’s code word for those prisoners who were never recorded as having been detained.
  • The conspiracy intentionally failed to record persons as detained at Abu Ghraib in order to try to prevent the Red Cross from visiting with them and learning of the torture.
  • Reasonable discovery will establish that CACI employees repeatedly conspired with military personnel to give Plaintiffs the “special treatment,” which was code for torture of the type endured by Plaintiffs in the hard site.
  • CACI employees repeatedly conspired with military personnel to harm Plaintiffs in the various manners and methods referred to above.
  • The acts of CACI employees constitute acts of CACI. CACI conveyed its intent to join the conspiracy, and ratified its employees’ participation in the conspiracy, by making a series of verbal statements and by engaging in a series of criminal acts of torture alongside and in conjunction with several co-conspirators.

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