IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 1066

Consent MOTION for Extension of Time to File Answer, Consent MOTION for Extension of Time to File Response/Reply to Order to Show Cause by GHANIM-ABDULRAHMAN AL-HARBI, ZAINULABIDIN MEROZHEV, GUANTANAMO BAY DETAINEE LITIGATION (Lefrak, Allison)

IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Doc. 1066

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Ghanim-Abdulrahman al-Harbi, et al., Petitioners, v. George W. Bush, et al., Respondents.

Civil Action No: 05-CV-2479 (HHK) Civil Action Misc. No. 08-442 (TFH)

CONSENT REQUEST FOR FURTHER EXTENSION OF TIME On November 21, 2008, Petitioner Zainulabidin Merozhev requested an extension of time within which to file his response to the Court's order of November 13, 2008 directing petitioner to show cause why his petition should not be dismissed as a result of his transfer from Guantanamo to Tajikistan. Counsel for petitioner requested an extension of time up to and including December 5, 2008 within which to respond to the Court order to show cause. Petitioner's counsel was unable to consult with respondent's counsel prior to filing the request. Counsel for petitioner is advised that Mr. Merozhev remains in custody of the security agency of Tajikistan, and counsel has not been able to communicate with him since his transfer. On November 24, 2008, Counsel for petitioner spoke to counsel for respondent, Mr. Andrew Warden, by telephone. Mr. Warden consented to petitioner's request for sixty (60) days within which to file a response to the Court order to show cause. For these reasons, Petitioner Merozhev respectfully requests this Court grant him an extension to file his response to the Court's order to show cause, up to and including January 23, 2008.

US_ACTIVE-100840923.1-AMLEFRAK-304800-50058 11/26/08 12:49 PM

Dockets.Justia.com

Respectfully submitted, Dated: November 26, 2008 /s/ Allison M. Lefrak Douglas K. Spaulding Gary S. Thompson Allison M. Lefrak Rick W. Roberts Nathan R. Fennessy REED SMITH LLP 1301 K Street, NW Suite 1100 ­ East Tower Washington, DC 20005 Phone: [phone] Bernard J. Casey, D.C. Bar No. 112219 Casey ADR Services 3018 NE 32nd Place Portland, OR 97212 Phone: [phone] - and ­ CENTER FOR CONSTITUTIONAL RIGHTS Gitanjali S. Gutierrez (NY1234) 666 Broadway, 7th Floor New York, New York 10012 Tel: [phone] Counsel for Petitioners

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CERTIFICATE OF SERVICE I hereby certify that the foregoing was served by Electronic Case Filing this 26th day of November 2008. /s/ Allison M. Lefrak Allison M. Lefrak

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Ghanim-Abdulrahman al-Harbi, et al., Petitioners, v. George W. Bush, et al., Respondents.

Civil Action No: 05-CV-2479 (HHK) Civil Action Misc. No. 08-442 (TFH)

ORDER Upon consideration of petitioner Zainulabidin Merozhev's request for an extension of time and any opposition thereto, it is by the Court this __ day of December Ordered that the motion be and it is hereby granted and petitioner shall have up to and including January 23, 2008 to respond to the court's show cause order dated November 13, 2008.

______________________________ U.S. District Judge

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