IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 1170

MOTION for Extension of Time to File Response/Reply as to 1001 MOTION for Discovery by GUANTANAMO BAY DETAINEE LITIGATION (Attachments: # 1 Text of Proposed Order)(Stander, David)

IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Doc. 1170

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. 05-1429 (RMU)

UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO PETITIONER'S MOTION FOR ADDITIONAL DISCOVERY Respondents hereby move for an extension of time, until December 4, 2008, to respond to Petitioner's Motion for Additional Discovery. In support of this motion, Respondents submit the following: 1. On November 18, 2008, Petitioner filed a Motion for Additional Discovery

pursuant to Section I.E.2 of the Case Management Order. By order of the Court, Respondents response to that motion is due today, December 2, 2008. 2. Respondents seek an extension of two days ­ until December 4, 2008, to respond

to Petitioner's filings. Such an extension is necessary for Respondents to fully respond to the Petitioner's submissions. 3. Pursuant to Local Civil Rule 7.1(m), Respondents counsel has conferred with

counsel for Petitioner, who consents to the requested extension.

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4.

For the reasons stated above, Respondents respectfully request that the Court

extend until December 4, 2008, the time period during which Respondents may respond to Petitioner's above-captioned motion. A proposed order is attached. Dated: December 2, 2008 Respectfully submitted, GREGORY KATSAS Assistant Attorney General DOUGLAS N. LETTER Terrorism Litigation Counsel /s/ David J. Stander JOSEPH H. HUNT (D.C. Bar No. 431134) VINCENT M. GARVEY (D.C. Bar No. 127191) TERRY M. HENRY PAUL AHERN DAVID J. STANDER Attorneys United States Department of Justice Civil Division, Federal Programs Branch P.O. Box 883 Washington, DC 20044 Tel: [phone] Attorneys for Respondents

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