IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 498

Unopposed MOTION for Extension of Time to Comply with Court's Order of July 29, 2008 by ABDUL-RAHMAN ABDO ABULGHAITH SULAIMAN, ACHRAF SALIM ABDESSALAM (Attachments: # 1 Exhibit A--Proposed Order)(Sullivan, Thomas)

IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Doc. 498

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA IN RE: GUANTÁNAMO BAY DETAINEE LITIGATION ) ) ) ) ) )

Misc. No. 08-442 (TFH) Civil Action No. 05-CV-2386 (RBW) Civil Action No. 06-CV-1761 (ESH)

UNOPPOSED MOTION FOR EXTENSION OF TIME Petitioner Abdul-Rahman Sulaeiman, one of the petitioners in Mohammon v. Bush, 052386, and Petitioner Achraf Salim Abdessalam, the petitioner in Abdessalam v. Bush, 06-1761, respectfully request a one-week extension of time until October 6, 2008, for counsel to file the authorization or counsel's declaration pursuant to the Court's Order of July 29, 2008. In support of this motion, counsel for Petitioners states: 1. On July 29, 2008, counsel for Petitioners, Thomas P. Sullivan and Douglas A.

Sondgeroth, requested approval from the Government to travel to Guantánamo Bay to meet with Petitioner Abdessalam on September 30, 2008, and with Petitioner Sulaeiman on October 1, 2008. The Government approved that request on September 4, 2008. 2. During the meetings with Petitioners, counsel will discuss with each of the

Petitioners the circumstances of their respective cases as well as the authorizations that this Court has ordered. 3. After meeting with Petitioners in person, counsel anticipates it will be better able

to provide the authorization or declaration requested by the Court's order of July 29, 2008. Accordingly, petitioners request a one-week extension of time until October 6, 2008 to comply with the Court's Order of July 29, 2008. A proposed order is attached as Exhibit A.

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4.

Pursuant to Local Rule 7(m), counsel for Petitioners has contacted counsel for

Respondents regarding this motion and counsel for respondents has stated that respondents consent to Petitioners' request for an extension.

Dated: September 23, 2008

Respectfully submitted, /s/ Thomas P. Sullivan One of the Attorneys for Petitioners Abdul-Rahman Sulaeiman and Achraf Salim Abdessalam Thomas P. Sullivan Douglas A. Sondgeroth JENNER & BLOCK LLP 330 North Wabash Ave. Chicago, IL 60611 Tel: [phone] Fax: [phone]

2

CERTIFICATE OF SERVICE I hereby certify that on September 23, 2008, I caused the foregoing Unopposed Motion for Extension of Time to be delivered to the below-listed counsel of record in the abovecaptioned matters through the CM/ECF system: Andrew I. Warden United States Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Avenue NW Washington, D.C. 20530 Terry Marcus Henry United States Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Avenue NW Washington, D.C. 20530

/s/ Thomas P. Sullivan