MAQALEH et al v. RUMSFELD et al

Filing 6

Consent MOTION for Extension of Time to respond to 5 First Amended Petition for a Writ of Habeas Corpus by ROBERT GATES, DONALD RUMSFELD, JOHN DOE, JOHN DOE 2. (Attachments: # 1 Text of Proposed Order)(Lin, Jean) Modified on 3/2/2007 (zlc, ).

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MAQALEH et al v. RUMSFELD et al Doc. 6 Case 1:06-cv-01669-JDB Document 6 Filed 03/01/2007 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) ) ) ) ) ) FADI AL MAQALEH, Petitioner, v. DONALD RUMSFELD, et al., Respondents. Civil Action No. 06-CV-01669 (JDB) RESPONDENTS' UNOPPOSED MOTION FOR EXTENSION OF TIME Respondents hereby move, through undersigned counsel, for an order extending their deadline to file a response to petitioner's First Amended Petition for a Writ of Habeas Corpus through and including March 9, 2007. In support of this motion, respondents inform the Court as follows: 1. In the absence of the requested extension, a response to the First Amended Petition would be due on March 2, 2007. 2. Respondents' counsel are attempting to secure an up-to-date declaration in support of their response to the First Amended Petition. 3. The petition relates to matters occurring at the Bagram Airfield in Afghanistan, Consequently, the process of securing the necessary declaration is difficult and has been rendered more so by last minute logistical obstacles that have arisen, including the current unavailability of the person whom counsel believe will be the declarant. 4. Petitioner's counsel has authorized the undersigned to represent to the Court that she consents to the requested extension. Case 1:06-cv-01669-JDB Document 6 Filed 03/01/2007 Page 2 of 2 Dated: March 1, 2007 Respectfully submitted, PETER D. KEISLER Assistant Attorney General DOUGLAS N. LETTER Terrorism Litigation Counsel /s/ Jean Lin JOSEPH H. HUNT (D.C. Bar No. 431134) VINCENT M. GARVEY (D.C. Bar No. 127191) JUDRY L. SUBAR (D.C. Bar No. 347518) JEAN LIN Attorneys United States Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Ave., N.W. Washington, DC 20530 Tel: (202) 514-3716 Fax: (202) 616-8470 Attorneys for Respondents 2

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