RUZATULLAH v. RUMSFELD et al

Filing 27

RUZATULLAH v. RUMSFELD et al

Doc. 27

Case 1:06-cv-01707-GK

Document 27

Filed 08/13/2007

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) Petitioners, ) ) v. ) ) DONALD RUMSFELD, ) Secretary, United States Department of ) Defense, et al., ) ) Respondents. ) ) RUZATULLAH, et al.,

Civil Action No. 06-CV-01707 (GK)

RESPONDENTS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO REPLY TO PETITIONER'S OPPOSITION TO RESPONDENTS' SUPPLEMENTAL MOTION TO DISMISS Respondents, through undersigned counsel, move for an extension of time from August 14, 2007 to and including September 5, 2007, within which to respond to Petitioner's Opposition to Respondents' Supplemental Motion to Dismiss. In support of this motion, respondents inform the Court as follows: 1. On October 2, 2006, a habeas petition was filed on behalf Ruzatullah and another

citizen of Afghanistan who were detained by the United States at Bagram Airfield in Afghanistan. The habeas petition was subsequently amended twice, and briefing on respondents' motion to dismiss the Second Amended Petition was complete on April 20, 2007. 2. On July 7, 2007, respondents filed a supplement to their motion to dismiss,

informing the Court that on or about June 19, 2007, the United States transferred petitioner Ruzatullah to the Government of Afghanistan, relinquishing all legal and physical custody of Ruzatullah. Respondents further argued that Ruzatullah's habeas petition is therefore moot.

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Case 1:06-cv-01707-GK

Document 27

Filed 08/13/2007

Page 2 of 2

3.

This Court set a briefing schedule for petitioner Ruzatullah's response, which

schedule was later reset upon petitioner's consent motion. On August 2, 2007, petitioner Ruzatullah filed his response, and pursuant to the Court's briefing schedule, respondents' reply is currently due on August 14, 2007. 4. Respondents anticipate that they will not be able to meet that deadline because

petitioner's opposition raises many factual matters that have required, and will require, some time to investigate. Moreover, preparation of respondents' reply will require the input of multiple components of the government, but many people that would need to be involved in this process are unavailable at various times in August. 5. Petitioners' counsel has authorized the undersigned to represent to this Court that

they do not oppose the present motion. Dated: August 13, 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. Room 7120 Washington, DC 20530 Tel: [phone] Fax: [phone] Attorneys for Respondents 2