Government provided verbal assurances that it never detained the Complainant in
Djibouti.
105. With regard to statements made by Tanzanian officials during the habeas
corpus proceedings, the Respondent State wonders how Tanzanian officials could
have deported a Yemen citizen to its territory as an alleged destination of his choice
without obtaining prior permission and when the Complainant himself had never
been to Djibouti.
106. Commenting on the Complainant’s set of circumstantial evidence indicating
that that he was detained at Camp Lamonnier, the Respondent State observes first
that the Complainant’s testimony is inconsistent with the reality regarding the
location of Camp Lamonnier. In particular, referring to a satellite image of the
Ambouli International Airport (introduced with the Reply) where Camp Lamonnier
is located, the Respondent State observes that driving from the airport to Camp
Lamonnier cannot take up to twenty let alone thirty minutes as the Complainant
alleges was the case on his arrival and depart from Djibouti. It stressed that the drive
should take no more than a minute or two from the airstrip to anywhere else at the
base of Camp Lamonnier.
107. Secondly, using the same satellite image, the Respondent State observes that
the description by the Complainant that the place of his secret detention was likely
in a residential area is inconsistent with geographic realities of Camp Lamonnier,
which is located far from any residential areas. Even more strikingly, so observes the
Respondent State, is the fact that the Complainant never stated that he heard any
sounds of airplanes as one would expect in the immediate vicinity of a busy civilian
and military airport such as Ambouli International Airport. It maintains, that the
Complainant has not presented any reliable evidence that he was at Camp
Lamonnier, let alone anywhere in Djibouti.
108. With respect to the reports by various organisations on which the
Complainant relies to corroborate that he was detained in Djibouti as part of the U.S.
Government’s extraordinary rendition program, the Respondent State, observes that
such reports are weak in that they cautiously do not conclusively establish Djibouti’s
involvement in the alleged U.S. Government’s extraordinary rendition program.
Similarly it argues that media reports are no more than a recycling of the
Complainant’s own interviews with media outlets and as submitted in the present
Communication.
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