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[casi-analysis] casi-news digest, Vol 1 #135 - 2 msgs

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Today's Topics:

   1. The Lancet / Editorial (Hassan)
   2. Abu Ghraib: its legacy for military medicine (Hassan)


Message: 1
Date: Fri, 20 Aug 2004 10:05:56 -0700 (PDT)
From: Hassan <>
Subject: The Lancet / Editorial
To: CASI newsclippings <>,
  IAC discussion <>


How complicit are doctors in abuses of detainees?

Almost 3 years ago, we asked, "Does the western world
still take human rights seriously?" We did so in
response to the UK's 2001 Anti-terrorism, Crime, and
Security Act, which itself was a reaction to the
events of Sept 11 that year. We were disturbed by a
Newsweek columnist's suggestion that the use of
torture on suspected terrorists should be considered
as a legitimate means of obtaining information. As
more details about the treatment of detainees in the
Abu Ghraib prison in Iraq and the US Guantanamo Bay
detention centre in Cuba come to light, disquiet about
contemplating or debating the use of torture to secure
information has given way to certainty that this is
precisely what took place under US command. The answer
to our question posed three years ago is clearly "no";
human rights have become a casualty in the desperate
attempt to get results in the war against terrorism.
The question we now need to ask is, what part have
doctors played in these abuses?

The UK Court of Appeal ruled last week in a two-to-one
judgment that evidence obtained by torture is
admissible as long as it is not procured by British
officials. The ruling was made in response to an
appeal brought by 10 foreign nationals detained in the
UK for more than 2 years without charge or trial under
the Anti-terrorism, Crime and Security Act. The
dissenting judge, Lord Justice Neumeister, argued that
"by using torture or even by adopting the fruits of
torture, a democratic state is weakening its case
against terrorists, by adopting their methods, thereby
losing the moral high ground an open democratic
society enjoys". The case will almost certainly go on
to the House of Lords.

Currently, 585 people are held in Guantanamo Bay
without charge and many have been there for 2 years or
longer. 156 have so far been released. The official
number of suicide attempts is given as 34. None has
been successful because detainees are checked by
guards every 45 s. According to the Guantanamo Bay
press officer, about 10% are receiving counselling or
medical treatment for mental illness. However the
number of detainees with mental health problems may be
much higher, given the details of detention conditions
and methods of interrogations that are coming to light
through the reports of those released. Lawyers for
three UK citizens arrested in Afghanistan and held in
Guantanamo Bay, who were sent back to the UK in March
this year only to be released without charges by UK
authorities, have compiled a report based on
interviews with their clients. This report describes
how confessions that were later proven by MI5 to be
false were made allegedly under coercive conditions.
How can the UK Home Secretary David Blunkett and the
Court of Appeal justify using, for example, such
evidence to detain people indefinitely?

Even more disturbing is the emerging evidence that
doctors and other medical personnel have helped,
covered up, or stood by silently when humiliation,
degrading treatment, and physical abuses have taken
place. As Steven Miles describes in this week's issue
of The Lancet, there are now reports of medical
personnel in Afghanistan and Iraq allegedly abusing
detainees, falsifying and delaying death certificates,
and covering up homicides. No unprompted reports of
abuses were initiated by medical personnel before the
official investigation into practices at Abu Ghraib.
At Guantanamo Bay, medical records were routinely
shared with interrogators in a clear breach of
confidentiality and with the knowledge that such
information can be misused despite objections by the
medical team of the International Committee of the Red
Cross, who in protest suspended their medical visits.

Military doctors can be placed in a difficult
position, but the problem of dual loyalty, to patients
and to their employers, is well recognised. Guidelines
and codes of practice state that doctors, even in
military forces, must first and foremost be concerned
about their patients and bound by principles of
medical ethics. Given these events, the World Medical
Association saw the need to re-emphasise its strong
and unambiguous 1975 Tokyo Declaration in June:
"Doctors shall not countenance, condone, or
participate in torture or other forms of degrading
procedures . . . in all situations, including armed
conflict and civil strife". As one of the other few
medical bodies to speak out, members of Physicians for
Human Rights wrote an open letter on Aug 6 to James
Schlesinger, Chair of the independent panel to review
US Department of Defense detention operations (and due
to report later this month), questioning the role and
use of physicians and other medical personnel in
detention centres in Afghanistan, Iraq, and Guantanamo

Health-care workers should now break their silence.
Those who were involved in or witnessed ill-treatment
need to give a full and accurate account of events at
Abu Ghraib and Guantanamo Bay. Those who are still in
positions where dual commitments prevent them from
putting the rights of their patients above other
interests, should protest loudly and refuse
cooperation with authorities. The wider non-military
medical community should unite in support of their
colleagues and condemn torture and inhumane and
degrading practices against detainees. Abu Ghraib
should serve as an eleventh hour wake-up call for the
western world to rediscover and live by the values
enshrined in its international treaties and democratic
constitutions. * The Lancet

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Message: 2
Date: Fri, 20 Aug 2004 10:10:08 -0700 (PDT)
From: Hassan <>
Subject: Abu Ghraib: its legacy for military medicine
To: CASI newsclippings <>,
  IAC discussion <>

Abu Ghraib: its legacy for military medicine

Steven H. Miles

The policies
The offences
The legacy

The complicity of US military medical personnel during
abuses of detainees in Iraq, Afghanistan, and
Guantanamo Bay is of great importance to human rights,
medical ethics, and military medicine. Government
documents show that the US military medical system
failed to protect detainees' human rights, sometimes
collaborated with interrogators or abusive guards, and
failed to properly report injuries or deaths caused by
beatings.1-23 An inquiry into the behaviour of medical
personnel in places such as Abu Ghraib could lead to
valuable reforms within military medicine.
The policies

As the Bush administration planned to retaliate
against al-Qaeda's terrorist attacks on the USA, it
was reluctant to accept that the Geneva Convention
Relative to the Treatment of Prisoners of War would
apply to al-Qaeda detainees.24 In January, 2002, a
memorandum from the US Department of Justice to the
Department of Defense concluded that since al-Qaeda
was not a national signatory to international
conventions and treaties, these obligations did not
apply.4 It also concluded that the Convention did not
apply to Taliban detainees because al-Qaeda's
influence over Afghanistan's government meant that it
could not be a party to treaties. In February, 2002,
the US president signed an executive order stating
that although the Geneva Conventions did not apply to
al-Qaeda or Taliban detainees, "our nation . . . will
continue to be a strong supporter of Geneva and its
principles . . . the United States Armed Forces shall
continue to treat detainees humanely and, to the
extent appropriate and consistent with military
necessity in a manner consistent with the principles
of Geneva."5 This phrasing subordinates US compliance
to the Geneva Convention to undefined "military

An August, 2002 Justice Department memorandum to the
President and a March, 2003 Defense Department Working
Group distinguished cruel, inhumane, or degrading
treatment, which could be permitted in US military
detention centres, from torture, which was ordinarily
banned except when the President set aside the US
commitment to the Convention in exercising his
discretionary war-making powers.3,7 These memoranda
semantically analysed the words "harm" or "profound
disruption of the personality" in legal definitions of
torture without grounding the terms on references to
research showing the prevalence, severity, or duration
of harm from abusing detainees.25-30 Also, the
memoranda do not distinguish between coercive
interrogation involving soldiers from those employing
medical personnel or expertise. For example, both
documents excuse the use of drugs during
interrogation.3,7 Neither document mentions medical
ethics codes or the history of medical or psychiatric
complicity with torture or inhumane

In late 2002, the Secretary of Defense approved
"Counter Resistance Techniques" including nudity,
isolation, and exploiting fear of dogs for
interrogating al-Qaeda suspects at Guantanamo.6 In
April, he revised those techniques and advised those
devising interrogation plans to give consideration to
the view of other countries that some of the
authorised techniques such as threats, insults, or
intimidation violate the Geneva Convention. He added,
"Nothing in this memorandum in any way restricts your
existing authority to maintain good order and
discipline among detainees."6 .

The Interrogation Rules of Engagement posted at Abu
Ghraib stated: "[Interrogation] Approaches must always
be humane . . . Detainees will NEVER be touched in a
malicious or unwanted manner . . . the Geneva
Conven-tions apply."11 These rules were imported from
the US operation in Afghanistan and echoed the 2003
memo by the Secretary of Defense. They stated:
"Wounded or medically burdened detainees must be
medically cleared prior to interrogation" and approved
"Dietary mani-pulation (monitored by med)" for
interrogation.11 Defense Department memoranda define
the latter as substituting hot meals to cold field
rations rather than food deprivation but there are
credible reports of food deprivation.6,19,33

Although US military personnel receive at least 36
min-utes of basic training on human rights, Abu Ghraib
military personnel did not receive additional human
rights training and did not train civilian
interrogators working there.1,15,17 Military medical
personnel in charge of detainees in Iraq and
Afghanistan denied being trained in Army human rights
policies.17 Local commanding officers were unfamiliar
with the Geneva Convention or Army Regulations
regarding abuses.13-15 Arab language synopses of
Geneva protections were not posted in the cellblocks
in Iraq and Afghanistan as required by Army

The offences

Confirmed or reliably reported abuses of detainees in
Iraq and Afghanistan include beatings, burns, shocks,
bodily suspensions, asphyxia, threats against
detainees and their relatives, sexual humiliation,
isolation, prolonged hooding and shackling, and
exposure to heat, cold, and loud
noise.1,14,19,24,33,34 These include deprivation of
sleep, food, clothing, and material for personal
hygiene, and denigration of Islam and forced violation
of its rites.19 Detainees were forced to work in areas
that were not de-mined and seriously injured.34 Abuses
of women detainees are less well documented but
include credible allegations of sexual humiliation and

US Army investigators concluded that Abu Ghraib's
medical system for detainees was inadequately staffed
and equipped.8,11,13,16,17 The International Committee
of the Red Cross (ICRC) found that the medical system
failed to maintain internment cards with medical
information necessary to protect the detainees' health
as required by the Geneva Convention; this reportedly
was due to a policy of not officially processing (ie,
recording their presence in the prison) new
detainees.16,34 Few units in Iraq and Afghanistan
complied with the Geneva obligation to provide monthly
health inspections.17 The medical system also failed
to assure that prisoners could request proper medical
care as required by the Geneva Convention. For
example, an Abu Ghraib detainee's sworn document says
that a purulent hand injury caused by torture went
untreated. The individual was also told by an Iraqi
physician working for the US that bleeding of his ear
(from a separate beating) could not be treated in a
clinic; he was treated instead in a prison hallway.20

The medical system failed to establish procedures, as
called for by Article 30 of the Geneva Convention, to
ensure proper treatment of prisoners with
disabilities. An Abu Ghraib prisoner's deposition
reports the crutch that he used because of a broken
leg was taken from him and his leg was beaten as he
was ordered to renounce Islam. The same detainee told
a guard that the prison doctor had told him to
immobilise a badly injured shoulder; the guard's
response was to suspend him from the shoulder.21

The medical system collaborated with designing and
implementing psychologically and physically coercive
interrogations. Army officials stated that a physician
and a psychiatrist helped design, approve, and monitor
interrogations at Abu Ghraib.15 This echoes the
Secretary of Defense's 2003 memo ordering
interrogators to ensure that detainees are "medically
and operationally evaluated as suitable" for
interrogation plans.6 In one example of a compromised
medically monitored interrogation, a detainee
collapsed and was apparently unconscious after a
beating, medical staff revived the detainee and left,
and the abuse continued.22 There are isolated reports
that medical personnel directly abused detainees. Two
detainees' depositions describe an incident where a
doctor allowed a medically untrained guard to suture a
prisoner's lacertation from being beaten.22,23

The medical system failed to accurately report
illnesses and injuries.34 Abu Ghraib authorities did
not notify families of deaths, sicknesses, or
transfers to medical facilities as required by the
Convention.34,36 A medic inserted a intravenous
catheter into the corpse of a detainee who died under
torture in order to create evidence that he was alive
at the hospital.37 In another case, an Iraqi man,
taken into custody by US soldiers was found months
later by his family in an Iraqi hospital. He was
comatose, had three skull fractures, a severe thumb
fracture, and burns on the bottoms of his feet. An
accompanying US medical report stated that heat stroke
had triggered a heart attack that put him in a coma;
it did not mention the injuries.38

Death certificates of detainees in Afghanistan and
Iraq were falsified or their release or completion was
delayed for months.24,39 Medical investigators either
failed to investigate unexpected deaths of detainees
in Iraq and Afghanistan or performed cursory
evaluations and physicians routinely attributed
detainee deaths on death certificates to heart
attacks, heat stroke, or natural causes without noting
the unnatural aetiology of the death.40,41 In one
example, soldiers tied a beaten detainee to the top of
his cell door and gagged him. The death certificate
indicated that he died of "natural causes . . . during
his sleep." After news media coverage, the Pentagon
revised the certificate to say that the death was a
"homicide" caused by "blunt force injuries and

In November, 2003, Iraqi Major General Mowhoush's head
was pushed into a sleeping bag while interrogators sat
on his chest. He died; medics could not resuscitate
him, and a surgeon stated that he died of natural
causes.42 6 months later, the Pentagon released a
death certificate calling the death a homicide by
asphyxia.42 Medical authorities allowed misleading
information released by military authorities to go
unchallenged for many months.24 In 2004, the US
Secretary of Defense issued a stringent policy for
death investigations.43

Finally, although knowledge of torture and degrading
treatment was widespread at Abu Ghraib and known to
medical personnel,13,41,44 there is no report before
the January 2004 Army investigation of military health
personnel reporting abuse, degradation, or signs of

The legacy

Pentagon officials offer many reasons for these abuses
including poor training, understaffing, overcrowding
of detainees and military personnel, anti-Islamic
prejudice, racism, pressure to procure intelligence, a
few criminally-inclined guards, the stress of war, and
uncertain lengths of deployment.1,2,13,16,17
Fundamentally however, the stage for these offences
was set by policies that were lax or permissive with
regard to human rights abuses, and a military command
that was inattentive to human rights.

Legal arguments as to whether detainees were prisoners
of war, soldiers, enemy combatants, terrorists,
citizens of a failed state, insurgents, or criminals
miss an essential point. The US has signed or enacted
numerous instruments including the UN Universal
Declaration of Human Rights,45 the UN Body of
Principles for the Protection of All Persons under Any
Form of Detention or Imprisonment,46 UN Standard
Minimum Rules for the Treatment of Prisoners,36 the
Convention Against Torture and Other Cruel, Inhuman,
or Degrading Treatment or Punishment,47 and US
military internment and inter-rogation policies,8-10
collectively containing mandatory and voluntary
standards barring US armed forces from practicing
torture or degrading treatments of all persons.

For example, the Universal Declaration of Human Rights
states: "No one shall be subjected to torture or to
cruel, inhuman or degrading treatment or
punishment."45 The Geneva Convention states: "Persons
taking no active part in the hostilities, including
members of armed forces who have laid down their arms
and those placed hors de combat by sickness, wounds,
detention, or any other cause, shall in all
circumstances be treated humanely, without any adverse
distinction . . . The following acts are and shall
remain prohibited at any time and in any place
whatsoever with respect to the above-mentioned
persons: Violence to life and person, in particular
murder of all kinds, mutilation, cruel treatment and
torture; . . . Outrages upon personal dignity, in
particular, humiliating and degrading treatment . . .
No physical or mental torture, nor any other form of
coercion, may be inflicted on prisoners of war to
secure from them information of any kind whatever.
Prisoners of war who refuse to answer may not be
threatened, insulted, or exposed to any unpleasant or
disadvantageous treatment of any kind."48 Furthermore,
the US War Crimes Act says that US forces will comply
with the Annex to the Hague Convention Respecting the
Laws and Customs of War on Land and the Geneva
Convention Relative to the Treatment of Prisoners of
War both of which bar torture or inhumane

Pentagon leaders testified that military officials did
not investigate or act on reports by Amnesty
International and the ICRC of abuses at Abu Ghraib and
other coalition detention facilities throughout 2002
and 2003.1,24,33,34 The command at Abu Ghraib and in
Iraq was inattentive to human rights organisations'
and soldiers' oral and written reports of abuses.51
After the ICRC criticised the treatment of Abu Ghraib
detainees, its access to detainees was curtailed.1

The role of military medicine in these abuses merits
special attention because of the moral obligations of
medical professionals with regard to torture and
because of horror at health professionals who are
silently or actively complicit with torture. Active
medical complicity with torture has occurred
throughout the world. Physicians collaborated with
torture during Saddam Hussein's regime.52 Physicians'
and nurses' professional organisations have created
codes against participation in torture.25-26,31,53,54
Physicians in Chile, Egypt, Turkey and other nations
have taken great personal risks to expose
state-sponsored torture.25,26,55 Health professionals
have created organisations including Physicians for
Human Rights and Amnesty International's Health
Professionals Network. Numerous non-medical groups
have asserted that healers must be advocates for
persons at risk of torture.25,26,31,32,56

Military personnel treating prisoners of war face a
"dual loyalty conflict".57 The Geneva Convention
addresses this ethical dilemma squarely: "Although
[medical personnel] shall be subject to the internal
discipline of the camp . . . such personnel may not be
compelled to carry out any work other than that
concerned with their medical . . . duties."48 By this
standard, the moral advocacy of military medicine for
the detainees of the war on terror broke down.

If Abu Ghraib is to leave a legacy of reform, it will
be important to clarify how the breakdown occurred.
The emerging evidence points to policy and operational
failures. High-level Defense Department policies were
inattentive to human rights and to the ethical
obligations of medical care for detainees.6 One policy
empowered interrogators to evaluate and refuse the
request of a person under interrogation for medical
evaluation. Another directed clinicians to authorise
and monitor interrogations which, although proposed as
a safeguard, allowed medical judgment to determine the
harshness of interrogation.57 It will be important to
establish whether and how, senior military medical
officers reviewed, challenged, or tempered those

At the operational level, medical personnel evaluated
detainees for interrogation, and monitored coercive
interrogation, allowed interrogators to use medical
records to develop interrogation approaches, falsified
medical records and death certificates, and failed to
provide provide basic health care.58,59

Which medical professionals were responsible for this
misconduct? The US Armed Forces deploy physicians,
physicians' assistants, nurses, medics (with several
months of training), and various command and
administrative staff. International statements assert
that every health-care worker has an ethical duty to
oppose torture. For example, the UN Principles of
Medical Ethics Relevant to the Protection of Prisoners
Against Torture refers to "health personnel,"
"particularly physicians" but it also names
physicians' assistants, paramedics, physical
therapists and nurse practitioners.32 Likewise, the
Geneva Convention refers to the duties of physicians,
surgeons, dentists, nurses, and medical orderlies.48
Furthermore, the US Armed Forces medical services are
under physician commanders and each medic, as with
civilian physicians' assistants, is personally
accountable to a physician. Thus, physicians are
responsible for the policies of the medical system;
military medical personnel are should abide by the
ethics of medicine regarding torture.41

Abu Ghraib will leave a substantial legacy. Medical
personnel prescribed anti-depressants to and addressed
alcohol abuse and sexual misconduct in US soldiers in
the psychologically destructive prison milieu.44 The
reputation of military medicine, the US Armed Forces,
and the USA was damaged. The eroded status of
international law has increased the risk to
individuals who become detainees of war since Abu
Ghraib because it has decreased the credibility of
international appeals on their behalf.

Although the US Armed Forces' medical services are
mainly staffed by humane and skilled personnel, the
described offences do not merely fall short of medical
ideals; some constitute grave breaches of
international or US law. Various voices call for
courts martial, a special prosecutor, or compensation.
Such measures will be inadequate if unaccompanied by
even more ardently pursued reform.

Such reform must begin with a comprehensive
investigation. At this time, it is not possible to
know the absolute or relative prevalence of the
various abuses or fully assess the performance of
military medical personnel with regard to human rights
abuses. Army investigations have looked at a small set
of human rights abuses, but have not investigated
reports from human rights organisations, nor have they
focused on the role of medical personnel or examined
detention centres that were not operated by the
Army.13-17 Six more investigations are underway.59 The
Army's Miller and Ryder Investigations remain
classified.17 Several thousand pages of the Army's
Taguba Investigation appendices are unavailable.13
Several secret detention centres that remain
unmonitored. The US military medical services, human
rights groups, legal and medical academics, and health
professional associations should jointly and
comprehensively review this material in light of US
and international law, medical ethics, the military
code of justice, military training, the system for
handling reports of human rights abuses, and standards
for the treatment of detainees. Reforms stemming from
such an inquiry could yet create a valuable legacy
from the ruins of Abu Ghraib.

1 Senate and House Armed Services Committee.
Transcripts of Open Hearings. May 7, 11, 19, 2004. iraqfront.html
(accessed July 6, 2004).

2 Taguba Testimony US Senate. Transcribed by
eMediaMillWorks Inc.
(accessed July 8, 2004).

3 Department of Defense. Working Group Report on
Detainee Interrogations in the Global War on
Terrorism: Assessment of Legal, Historical, Policy and
Operational Considerations. March 6, 2003. (accessed June 17,

4 Deputy Assistant Attorney General. Memorandum for
General Counsel Secretary of Defense. Application of
Treaties and Laws to al-Qaeda and Taliban Detainees.
January 9, 2002. www.msnbc. (accessed June 15,

5 Bush G. Memorandum for the Vice President. Humane
Treatment of al Queda and Taliban Detainees.
com/wp-srv/nation/documents/ 020702bush.pdf (accessed
June 24, 2004).

6 A set of Department of Defense Department
correspondence with attachments.
documents/dodmemos.pdf (accessed July 8, 2004).

7 Office of the Assistant Attorney General. Memorandum
for Robert R Gonzales Counsel to the President. Re:
Standards of Conduct for Interrogation under 18 U.S.C.
2340-2340A. Aug 1, 2002. US Department of Justice,
Office of Legal Counsel. http://www.
dojinterrogationmemo20020801.pdf (accessed June 17,

8 Military Police Internment/Resettlement Operations
FM 3-19.40
(accessed July 4, 2004).

9 US Army Field Manual 1987 34-52. Chapter 1.
Interrogation and the Interrogator.
policy/army/fm/fm34-52/chapter1.htm (accessed July 6,

10 Army Regulations. Enemy Prisoners of War, Retained
Personnel, Civilian Internees and Other Detainees. au/awc/awcgate/law/ar190-8.pdf

11 Joint Interrogation & Debriefing Center slides.
(accessed July 19, 2004).

12 Proper treatment of the Iraqi people during combat
operations. Brigadier General Karpinski (Abu Ghraib,
January 19, 2004.
(accessed July 19, 2004).

13 Article 15-6 Investigation of the 800th Military
Police Brigade (The Taguba Report).
tagubarpt.html#FRother2.19 (accessed July 21, 2004).

14 Captain Donald J. Reese's sworn statement and
interview. (Appendix to Taguba investigation)
articles/040709/CPT_Reese.pdf (Accessed July 19,

15 Colonel Thomas M. Pappas' sworn statement and
interview. (Appendix to Taguba investigation)
usnews/news/articles/040709/Pappas.pdf (accessed July
19, 2004).

16 Maj. David W. DiNenna's sworn statement and
interview. (Appendix to Taguba investigation)
articles/040709/ss-dinenna.pdf (accessed July 19,

17 US Army Inspector General.Detainee Operations
Investigation July 21,
2004 (accessed July 29,

18 Preferred charges against Specialist Jeremy Sivits,
Corporal Charles Graner, Sergeant Javal Davis.
news/world/iraq/prison-probe.htm (accessed July 6,

19 Sworn statements of Abu Ghraib detainees.
swornstatements042104.html (accessed June 29, 2004).

20 Sworn statement of Abu Ghraib Detainee #...1430/21
Jan 04.
abughraib/10.pdf (accessed July 8, 2004).

21 Sworn statement of Abu Ghraib detainee Ameen Sa'eed
Al-Sheikh given on January 16, 2004.
(accessed July 8, 2004).

22 Sworn statement of Abu Ghraib detainee Shalan Said
Alsharoni, Detainee #150422, 1630/17 Jan 04.
com/wp-srv/world/iraq/abughraib/150422.pdf (accessed
July 21, 2004).

23 Sworn statement of Abu Ghraib detainee Mustafa
Jassim Mustafa, Detainee #150542, 1610/17 Jan 04.
com/wp-srv/world/iraq/abughraib/150542-1.pdf (accessed
July 21, 2004).

24 Human Rights Watch. The Road to Abu Ghraib. June
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Other Cruel, Inhuman or Degrading Treatment or
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Adopted by the 29th World Medical Assembly Tokyo,
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32 United Nations General Assembly. Principles of
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against torture (1983)
(accessed June 15, 2004).

33 Amnesty International. Iraq: Memorandum on Concerns
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(accessed June 15, 2004).

34 International Committee of the Red Cross. Report of
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and Other Protected Persons by the Geneva Convention
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35 Harding L. Focus shifts to jail abuse of women. The
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36 First United Nations Congress on the Prevention of
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(accessed June 18, 2004).

37 Springer J. MP Captain Tells of Efforts to Hide
Details of Detainee's Death. Washington Post June 25,
2004; Page A18

38 Fisher I. Searing uncertainty for Iraqis' missing
loved ones. New York Times. June 1, 2004 A1,8.

39 Myers SL, Jehl D, Schimitt E, Zernike K. Military
completed death certificates for 20 prisoners only
after months passed. New York Times May 31, 2004. A8.

40 Harding L. How Abu Ghraib torture victim faces
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