MOHAMMED et al v. RUMSFELD
Consent MOTION for Extension of Time to File Response/Reply as to 4 MOTION to Dismiss for Lack of Jurisdiction and Respondents' Response to Order to Show Cause by HASAN BALGAID, OMAR DEGHAYES, SALIH, MUHAMMED DAWOOD, AMINULLAH, HAMID ULLAH, HAJI QIBULLAH, ZAFIR KHAN, GHULAM MOHAMMED, GHANUM GUL, ABDUL SALAAM, RAHEEM ULLAH, GUL REHMAN, FAZAL AHMAD, RAZ MOHAMMAD. (Goodman, William)
MOHAMMED et al v. RUMSFELD
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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญ x : GHULAM MOHAMMED, et al., : : Petitioners, : : v. : : DONALD RUMSFELD, : : Respondent. : : ญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญ x
Civil Action No. 06-CV-1680 (RJL)
FIRST MOTION FOR EXTENSION OF TIME ON CONSENT Petitioners, by and through their undersigned counsel, and with Respondent's consent, respectfully submit this motion for an extension of time to respond to Respondent's motion to dismiss this case for lack of jurisdiction (see dkt. no. 4). Petitioners request an extension of time until February 28, 2007. In support of this motion, Petitioners submit the following: 1. Petitioners have alleged that they are currently detained by the United
States at Bagram Airfield in Afghanistan. On September 29, 2006, Petitioners filed a habeas corpus petition challenging the legality of their detention ("Petition"). The Petition was
authorized in writing by Petitioners' friends and relatives, who act as their "next friends." 2. On November 24, 2006, the Court ordered Respondent to show cause why
the Petition should not be granted. 3. On December 22, 2006, Respondent filed a response to the order to show
cause and moved to dismiss this case for lack of jurisdiction (see dkt. no. 4).
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Pursuant to the Federal Rules of Civil Procedure and the Local Civil Rules
of this Court, Petitioners' response to the motion to dismiss is due on January 5, 2007. 5. Petitioners now seek an extension of time ญ until February 28, 2007 ญ to
respond to the motion to dismiss. Good cause exists for the Court to grant this motion because Respondent has indicated in his motion to dismiss that he is unable to confirm the identities of most (if not all) of the Petitioners as current detainees at Bagram. In particular, Respondent has indicated that he has no records or information concerning the detention of certain Petitioners at Bagram, and that other Petitioners have already been released from custody at Bagram (see dkt. no. 4, Ex. A). Although counsel is working diligently to investigate and resolve these issues, additional time is needed to do so fully and, if appropriate, to amend the Petition (or withdraw it as moot) before filing a response to the motion to dismiss on Petitioners' behalf. 6. Pursuant to Local Civil Rule 7(m), counsel have conferred via telephone
with Respondent's counsel, who have stated that they consent to this motion. 7. This is Petitioners' first request for an extension of time, and there are no
other previously scheduled deadlines that would be impacted by an order granting this motion. For all of these reasons, Petitioners respectfully request that the Court extend until February 28, 2007, the time period for them to respond to Respondent's motion to dismiss.
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New York, New York January 3, 2007 Respectfully submitted, Counsel for Petitioners: /s/ William Goodman William Goodman (Pursuant to LCvR 83.2(g)) CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, New York 10012 Tel: (212) 614-6464 Fax: (212) 614-6499
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