IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 1013

Consent MOTION to Stay of Proceedings for Ahmmed Ghulam Rabbani by AHMMED GHULAM RABBANI (Fryszman, Agnieszka)

IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Doc. 1013

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ______________________________ IN RE: GUANTANAMO BAY DETAINEE LITIGATION ) ) ) ) ) Misc. No. 08-0442 (TFH) Civil Action No. 05-1607 (RMU)

CONSENT MOTION FOR STAY OF PROCEEDINGS FOR AHMMED GHULAM RABBANI One of the two Petitioners in Rabbani v. Bush, Petitioner Ahmmed Ghulam Rabbani (ISN 1461), seeks an indefinite stay of all proceedings in his individual habeas matter. Respondents do not object to this Motion. Petitioner and Respondents agree that the obligations of both the movant and the Government under Judge Hogan's November 6, 2008 Case Management Order should be suspended with respect to this Petitioner unless and until the stay is lifted, and that either party may seek to lift the stay for any reason in the future. They also agree that during the pendency of the stay the Protective Order and 30-Day Notice Order already entered in Rabbani v. Bush, 05-CV-1607 (RMU), will remain operative with respect to this Petitioner. The remaining Petitioner in Rabbani v. Bush, Abdul Raheem Ghulam Rabbani (ISN 1460), does not seek a stay of the proceedings.

Dated: November 19, 2008 Washington, D.C.
___/s/ Agnieszka M. Fryszman________ Agnieszka M. Fryszman Matthew K. Handley Jason M. Leviton Matthew Kaplan COHEN MILSTEIN SELLERS & TOLL PLLC

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1100 New York, Ave., N.W. West Tower, Suite 500 Washington, D.C. 20005 Telephone: [phone] Facsimile: [phone] John Holland Anna Cayton-Holland LAW OFFICES OF JOHN HOLLAND 2150 W. 29th Ave., Suite 500 Denver, CO 80211 Telephone: [phone] Facsimile: [phone] Attorneys for Petitioner

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ______________________________ ) IN RE: ) GUANTANAMO BAY ) DETAINEE LITIGATION ) )

Misc. No. 08-0442 (TFH) Civil Action No. 05-1607 (RMU)

[PROPOSED] ORDER Before the Court is the Consent Motion for Stay of Proceedings filed by Petitioner Ahmmed Rabbani on November 19, 2008. Upon consideration of the Motion, it is this __ day of November, 2008, hereby ORDERED that the Motion is GRANTED and that proceedings for this Petitioner be stayed; and it is further ORDERED that the Protective Order and 30-Day Notice Orders previously entered in this case shall continue in effect during the pendency of the stay; and it is further ORDERED that either party may move the Court to lift the stay at any time in the future; and it is further ORDERED that this ORDER does not apply to Petitioner Abdul Raheem Ghulam Rabbani.

_________________________ Hon. Ricardo M. Urbina United States District Judge