1 Scottish Criminal Cases Review Comm’n News Release, Abdelbasset Ali Mohmed Al Megrahi (June 28, 2007), at <http://www.sccrc.org.uk/ViewFile.aspx?id=293>. The commission’s news release includes a multipage summary of the reasons for its conclusions. Under Scottish law, “the Commission has the power to refer to the High Court of Justiciary any conviction or sentence passed on a person, whether or not an appeal against the conviction or sentence has been heard and determined previously. The consequence of a reference is that the High Court hears an appeal in the case.” Id. at 11.

2 Alan, Cowell, Lockerbie Ruling Raises Questions on Libyan’s Guilt, N.Y. Times, June 29, 2007, at A1Google Scholar; Mary, Jordan, Libyan in Lockerbie Case Is Granted a New Hearing, Wash. Post, June 29, 2007, at A18.Google Scholar

3 U.S. Dep’t of State Daily Press Briefing (June 28, 2007), at <http://www.state.gOv/r/pa/prs/dpb/2007/jun/87531.htm>.

4 28 U.S.C. §1350 (2000).

5 See Anna, Gabrielidis, Alien Tort Statute Historical Precedents (unpublished memorandum, June 15, 2005), at <http://www.cja.org/legalResources/ATSdocs/ATSPrecedents.pdf>>Google Scholar, and cases cited there.

6 Juan, Forero, Unionists’ Murders Cloud Prospects for Colombia Trade Pact, Wash. Post, Apr. 10, 2007, at A9Google Scholar; Kyle, Whitmire, Suit in U.S. over Murders in Colombia, N.Y. Times, July 13, 2007, at C4Google Scholar; Juan, Forero, U.S. Firm on Trial in Colombia Slayings, Wash. Post, July 13, 2007, at A12Google Scholar; Juan, Forero, U. S. Firm Cleared in Deaths of 3 Colombians, Wash. Post, July 27, 2007, at A18.Google Scholar