Filing 1134

Memorandum in opposition to re (134 in 1:05-cv-00569-JR, 134 in 1:05-cv-00569-JR, 134 in 1:05-cv-00569-JR) MOTION for Reconsideration MOTION for Certification for interlocatory appeal MOTION to Stay filed by MOHAMMEDOU OULD SALAHI. (Attachments: # 1 Exhibit 1, # 2 Text of Proposed Order)(Duncan, Theresa)

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From: To: Subject: RE: Meet & Confer wrt 08-0442 Motion for Clarification and Reconsideration Date: Fri, 14 Nov 2008 17:17:58 -0500 Hello Mr. Johnson -Could you either send me a draft of your motion or tell me more specifically what you are getting at? Then we can tell you whether we consent or oppose. Sylvia Royce for the team representing Mohamedou Ould Slahi, No. 05cv0569 (202) 362-3445 (tel) (202) 686-4271 (fax) 5505 Connecticut Avenue, NW #340 Washington, DC 20015 USA Subject: Meet & Confer wrt 08-0442 Motion for Clarification and Reconsideration Date: Fri, 14 Nov 2008 13:25:53 -0500 From: To: CC: Counsel: In each of your cases in which the parties have not agreed to a stay, the government intends to file a motion for clarification and reconsideration of the Court's November 6, 2008 case management order (and supplemental amended orders, where applicable), or in the alternative, a motion for certification for appeal and to stay certain obligations pending appeal. The basis for this motion is that the November 6, 2008 procedural order is legally inappropriate and unworkable. Please advise if you oppose the motion by noon, ET, on Monday, November 17, 2008. When you respond, please indicate the case number and petitioner to which your response applies. Thank you. Timothy A. Johnson Trial Attorney U.S. Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Ave, NW, Rm 7328 Washington, DC 20530

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