QASSIM et al v. BUSH et al

Filing 47

QASSIM et al v. BUSH et al

Doc. 47

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ____________________________________ ) ABU BAKKER QASSIM, et al., ) ) Petitioners/Plaintiffs, ) Civil Action No. ) 05-0497 (JR) v. ) ) GEORGE W. BUSH, et al., ) ) Respondents/Defendants. ) ____________________________________) RESPONDENTS' UNOPPOSED MOTION FOR EXTENSION OF TIME Respondents hereby move for a one-week extension of time, until Friday, December 2, 2005, to file their opposition to Petitioners' Motion To Grant Them Access to Representatives of the United Nations Commission on Human Rights. Petitioners Abu Bakker Qassim and A'Del Abdul Hakim do not oppose respondents' request. Petitioners Qassim and Hakim filed their motion on November 10, 2005, which was marked as received by the Court Security Officer on November 14. Pursuant to the Court's Order dated May 15, 2005 (applying Amended Protective Order and Procedures for Counsel Access to Detainees at the United States Naval Base in Guantanamo Bay, Cuba, in In re Guantanamo Detainee Cases, 344 F. Supp. 2d 174 (D.D.C. 2004), and related orders, to this case), respondents' opposition to petitioners' motion is due to be filed on Friday, November 25, 2005. Due to the intervening Thanksgiving holiday on November 24, and the press of business on respondents' undersigned counsel in other

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litigation (in particular, the briefing of discovery disputes in California ex rel. Lockyer v. United States, No. 05-0328 (N.D. Cal.)), respondents seek a one-week extension of time, until Friday, December 2, 2005, to file their opposition to petitioners' motion. Pursuant to Local Rule 7(m), undersigned counsel spoke by telephone with counsel for petitioners, who indicated that petitioners do not oppose the extension of time sought herein. For the foregoing reasons, respondents' unopposed request for a one-week extension of time, until December 2, 2005, to file their opposition to petitioners' motion for access to representatives of the United Nations Commission on Human Rights, should be granted.

Dated: November 22, 2005

Respectfully submitted, PETER D. KEISLER Assistant Attorney General KENNETH L. WAINSTEIN United States Attorney DOUGLAS N. LETTER Terrorism Litigation Counsel

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/s/ James J. Gilligan JOSEPH H. HUNT VINCENT M. GARVEY TERRY M. HENRY JAMES J. SCHWARTZPREEYA M. NORONHA ROBERT J. KATERBERG NICHOLAS J. PATTERSON ANDREW I. WARDEN EDWARD H. WHITE JAMES J. GILLIGAN Attorneys United States Department of Justice Civil Division, Federal Programs Branch P.O. Box 883 Washington, D.C. 200044 Tel: [phone] Fax: [phone] Attorneys for Respondents

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