IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 1316

Unopposed MOTION for Leave to File Out of Time by SAEED MOHAMMED SALEH HATIM, ALI MOHAMMED SALEH AL-SALAHI (Attachments: # 1 Text of Proposed Order, # 2 Exhibit A)(Livingston, Schuyler)

IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Doc. 1316

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ____________________________________ ) IN RE: ) Misc. No. 08-0442 (TFH) GUANTANAMO BAY ) DETAINEE LITIGATION ) Civil Action No. 05-1429 (RMU) ____________________________________) MOTION FOR LEAVE TO FILE OUT OF TIME Respondents filed their Opposition to Petitioner's Motion for Discovery on December 4, 2008. In accordance with court rules, Petitioner's Reply Memorandum was due on December 11, 2008. However, due to an administrative oversight by counsel for Petitioners, Petitioners failed to file a reply by the prescribed deadline. Petitioners believe that the substance of their brief reply will be helpful to the Court in deciding the Motion for Discovery. Petitioners therefore request that the Court grant them leave to file their reply memorandum out of time. A copy of Petitioner's memorandum is attached as Exhibit A. Counsel for Respondents has been consulted and states that Respondents do not oppose the instant motion. December 16, 2008 /s/ S. William Livingston S. William Livingston D.C. Bar. No. 59055 Alan A. Pemberton D.C. Bar. No. 367108 COVINGTON & BURLING LLP 1201 Pennsylvania Ave., N.W. Washington, DC 20004-2401 [phone] (phone) [phone] (fax) [e-mail] [e-mail]

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David H. Remes D.C. Bar. No. 370372 APPEAL FOR JUSTICE 1106 Noyes Drive Silver Spring, MD 20910 [phone] (phone) [e-mail] Marc D. Falkoff D.C. Bar No. 491149 NORTHERN ILLINOIS UNIVERSITY COLLEGE OF LAW DeKalb, IL 60614 [phone] (phone) [phone] (fax) [e-mail]