IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 1616

STRICKEN PURSUANT TO MINUTE ORDER FILED 2/12/2009.....Unopposed MOTION for Extension of Time to File an Authorization or Counsel's Declaration Regarding His Representation by MULLAH NORULLAH NOORI (Sullivan, Patricia) Modified on 2/13/2009 (nmw, ).

IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Doc. 1616

UNITED STA TES DISTRI CT COUR T FOR THE DISTRICT OF COLUMBIA ______________________________ : IN RE: : : Mis c. No. 08-442 (TFH) GUANTANAM O BAY : DETAINEE LITIGATION : Civil Acti on No. 08-1828 (RMU) ______________________________: UNOPPOSED MOTION FOR EXTENSION OF TIME Pursuant to the Court's Order of December 12, 2008, Pet it ioner Mullah Noru llah Noori, ISN 006, (" Petit ioner"), through his undersigned counsel, respectfu lly requests an extension of time, until Ma rch 31, 2009, to file an authorizat ion or counsel's declarat ion regard ing h is representation. 1. The Court has ordered filing of authorizat ions or counsel's declarat ion regard ing

the representation of Petit ioners by February 12, 2009. 2. Petit ioner's counsel plan to visit Guantanamo Bay Nava l Stat ion (" GTMO" )

during the week of March 16, 2009 and will attempt to meet with Pet it ioner at that time. Assuming this meet ing goes forwa rd as scheduled, counsel w ill seek to obtain an executed authorization from the Petit ioner for the undersigned counsel to represent him. 3. Pursuant to Local Civil Rule 7(m), the undersigned counsel for Pet it ioner

conferred with Respondents' counsel re gard ing the re lief sought in this motion. Respondents' counsel have no objection to this motion. 4. Respondents agree to complete all pending d iscovery obligat ions under Sections

I.E.1. and I.D. 1. of Judge Hogan's Case Management Order dated November 6, 2008, as amended on December 16, 2008 (the " CMO"). Respondents will have no further discovery

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obligations, and Petit ioner agrees to hold off on further discovery requests, until the later of (1) March 31, 2009; or (2) the day the authorizat ion or counsel's declarat ion is filed. 5. Petit ioner's Tra verse w ill be due two weeks a fter the later of (1) Respondents

filing the notice cert ify ing that they have disc losed all exculpatory evidence under Section I.D.1. of the CMO; or (2) Petit ioner's counsel filing the authorizat ion or counsel's declarat ion thereof. 6. To a llow for adequate time to obtain a c leared authorization or counsel's

declarat ion, counsel request an extension of time until March 31, 2009 in which to file the authorization for the Petit ioner. Upon rece ipt of the declass ified authorizat ion, counsel w ill promptly file it w ith the Court. 7. Counsel currently are authorized to represent Petit ioner pursuant to the " next

friend" provis ion of the federal habeas statute. Respectfully submitted, /s/ Patric ia A. Sullivan Deming E. Sherman (#1138) Patricia A. Sullivan (#2120) EDWARDS ANGELL PALMER & DODGE LLP 2800 Financial Plaza Providence, RI 02903 Tel: [phone] Fax: [phone] [e-mail] [e-mail] Jared A. Goldstein ROGER WILLIAMS UN IVERSITY SCHOOL OF LAW Ten Met acom Avenue Bristol, RI 02809 Te l: [phone]

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Michael Ratner Shayana Kadidal J. Wells Dixon CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, New York 10012 Tel: [phone] Fax: [phone] Couns el for Petitioner

CERTIFICA TE OF SERVICE I hereby certify that on the 12th day of February, 2009, a t rue copy of the foregoing document was served upon each attorney of record in Misc. No. 08-442 (TFH ) and C.A. No. 081828(RM U), by electronic filing, via ECF, of th is document with the Unit ed States District Court for the District of Columbia:

/s/ Patric ia A. Sullivan

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