Filing 16

Consent MOTION for Extension of Time to File Response/Reply as to 13 MOTION to Dismiss or Transfer by PETER B. (Attachments: # 1 Text of Proposed Order)(Zaid, Mark)

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PETER B. v. CENTRAL INTELLIGENCE AGENCY et al Doc. 16 Case 1:06-cv-01652-RWR Document 16 Filed 05/07/2007 Page 1 of 1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA * * * Plaintiff, * * v. * Civil Action No. 06-1652 (RWR) * CENTRAL INTELLIGENCE AGENCY * et al. * * Defendants. * * * * * * * * * * * * * PLAINTIFF'S CONSENTED-TO MOTION FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADING PETER B. NOW COME Plaintiff, by and through his undersigned counsel, to respectfully request from this Court an extension up to and including May 31, 2007, in order to file a response to the defendants' Motion to Dismiss (filed March 26, 2007). Plaintiff's undersigned counsel, who is a solo practitioner, has been tentatively diagnosed with Lyme disease and remains ill. All efforts are being undertaken to timely respond to deadlines as best as possible but extensions are necessary as counsel attempts to address matters from the last 45 days during which time he has mostly been out of the office. Defendants' counsel has consented to this extension. The granting of this motion shall not result in the continuance of any hearing, conference or trial. A proposed Order accompanies this Motion. Date: May 6, 2007 Respectfully submitted, /s/ ________________________________ Mark S. Zaid, Esq. (D.C. Bar #440532) Mark S. Zaid, P.C. 1920 N Street, N.W., Suite 300 Washington, D.C. 20036 (202) 454-2809 Attorney for the Plaintiff

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