For a period of about eight months at Quantico, Manning was subjected to extraordinarily harsh conditions. This was done, the military claimed, for his own protection under a so-called “prevention of injury” order or POI.

The unidentified witnesses that Coombs wants to call include a military psychiatrist who consistently recommended to Manning’s captors at the brig at Quantico that the prisoner should be removed from restrictive conditions. But his advice was ignored and Manning continued to be subjected to solitary confinement, being stripped naked, held in a bare cell and made to wear a rough smock at night.

Witnesses will testify, the defense motion states, that when the psychiatrists objected to the conditions, they were told by the military chiefs in the brig: “We will do whatever we want to do.”

The defense also wants to call witnesses from Fort Leavenworth in Kansas where Manning was moved in April 2011 following an international outcry about his treatment.

After the move, the soldier was allowed much greater freedom under medium-security arrangements. The defense argues that his successful transfer shows “he was improperly held to begin with”.

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