PETER B. v. CENTRAL INTELLIGENCE AGENCY et al

Filing 17

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. 17 Case 1:06-cv-01652-RWR Document 17 Filed 05/30/2007 Page 1 of 2 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 a slight final extension of one week, or up to and including June 7, 2007, in order to file a response to the defendants' Motion to Dismiss (filed March 26, 2007).1 Plaintiff's undersigned counsel, who is a solo practitioner, is finally starting to recover from a diagnosis of Lyme disease and would be grateful for just one final slight extension which would allow him to address this and other pending matters. Additionally, counsel faced an office move that ended up taking more time than anticipated. 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. For clarification purposes the "filing" on this date is for counsel's submission of his response to the CIA for classification review. As soon as the document is returned the undersigned will immediately file it with the Court. 1 Dockets.Justia.com Case 1:06-cv-01652-RWR Document 17 Filed 05/30/2007 Page 2 of 2 Date: May 29, 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 ZaidMS@aol.com Attorney for the Plaintiff 2

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