engage a civilian attorney.1029 Those accused facing capital military commissions are also entitled to be assisted by “at least one additional” learned counsel.1030 ODIHR takes the view that a number of limitations placed on the defendants’ ability to choose a civilian counsel appear justified by reasonable and objective criteria, including the requirement to have a security clearance and not to have a disciplinary record. 401. In order to prepare their defence, accused persons are to have adequate time and facilities to communicate and consult with their lawyer.1031 Yet, information obtained by ODIHR points to numerous obstacles to an adequate and free attorney-client communication. Firstly, limitations are placed on lawyers’ ability to meet with or otherwise communicate with their clients. The remoteness of the base, and policies in place at Guantánamo, have impeded counsel’s ability to meet with their client in person. For example, attorneys must provide notice of every visit at least two weeks in advance, and meeting requests are reportedly often denied.1032 Moreover, attorney-client meetings are generally limited in duration and can only occur at certain hours of the day.1033 Whereas 16 meeting rooms are available for attorney-client meetings, it has been reported that only four to six meetings with “high-value detainees” can occur at the same time.1034 Accordingly, many counsel involved in military commission proceedings or habeas corpus petitions pertaining to the 16 “high-value detainees” have to compete for the meeting slots available.1035 In addition to these obstacles to frequent visits, defence counsel cannot communicate by telephone with defendants considered “high-value detainees”.1036 These limitations undermine the Epic Fail”, op. cit., note 709, p. 932. In meetings with ODIHR, representatives of the Office of the Chief Defense Counsel explained that, in practice, the only way defendants could choose their military defence counsel is to fire the one who has been detailed to their case to obtain a new one. They also stressed that the Office is understaffed: at the time of the meeting, it was authorized to have 51 military attorneys but only had 35. ODIHR meeting with the Department of Defense Office of the Chief Defense Counsel, op. cit., note 914. 1029 RMC, Rule 506(a). 1030 RMC, Rule 506(b). In this regard, representatives of the Office of Chief Defense Counsel however specified that the Government will only fund one civilian learned counsel per accused. ODIHR meeting with the Department of Defense Office of the Chief Defense Counsel, op. cit., note 914. In interviews with ODIHR, defence counsel have stressed that in ordinary federal courts, there are always at least two or more lawyers with experience in death penalty cases per defendant. ODIHR interview with Cheryl Bormann, Air Force Captain Michael Schwartz, Navy Reserves Lieutenant Commander James Hatcher and Tim Jon Semmerling, op. cit., note 725. 1031 ICCPR, Art. 14(3)(d); UN HRC, General Comment No. 32, op. cit., note 648, para. 32; “Body of Principles”, op. cit., note 89, Principle 18. 1032 Mark Denbeaux et al., “Spying on attorneys at GTMO: Guantanamo Bay Military Commissions and the Destruction of the Attorney-Client Relationship”, 12 April 2013, p. 8. <http://law.shu.edu/ProgramsCenters/PublicIntGovServ/policyresearch/upload/spying_on_attorneys_at_GTMO.pdf>; ODIHR interview with Cheryl Bormann, Air Force Captain Michael Schwartz, Navy Reserves Lieutenant Commander James Hatcher and Tim Jon Semmerling, op. cit., note 725; ODIHR meeting with the Department of Defense Office of the Chief Defense Counsel, op. cit., note 914; United States Military Commission, United States of America v. Mohammad et al., AE 008 (MAH), op. cit., note 845, p. 7. 1033 ODIHR meeting with the Department of Defense Office of the Chief Defense Counsel, ibid.; ODIHR interview with Cheryl Bormann, Air Force Captain Michael Schwartz, Navy Reserves Lieutenant Commander James Hatcher and Tim Jon Semmerling, ibid. See, also, United States Military Commission, United States of America v. Mohammad et al., AE 008 (MAH), ibid., p. 8, referring to ten meetings slots available in any given week. 1034 United States Military Commission, United States of America v. Mohammad et al., AE 008 (MAH), ibid., p. 7; ODIHR interview with Cheryl Bormann, Air Force Captain Michael Schwartz, Navy Reserves Lieutenant Commander James Hatcher and Tim Jon Semmerling, ibid.; ODIHR meeting with the Department of Defense Office of the Chief Defense Counsel, ibid. 1035 United States Military Commission, United States of America v. Mohammad et al., AE 008 (MAH), ibid., p. 7; ODIHR interview with Cheryl Bormann, Air Force Captain Michael Schwartz, Navy Reserves Lieutenant Commander James Hatcher and Tim Jon Semmerling, ibid. 1036 “Requests to Improve the Conditions of Confinement in Guantánamo”, Office of the Chief Defense Counsel, op. cit., note 424, p. 10; Wells Bennett, “Another Order in the 9/11 Case, This One On Legal Mail”, Lawfare website, 6 November 2013, 176