IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 611

Unopposed MOTION for Extension of Time to Respond to Motion For Leave to Amend Factual Return by OTHMAN ALI MOHAMMED AL SHAMRANY (Powell, Wesley)

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IN RE: GUANTANAMO BAY DETAINEE LITIGATION Doc. 611 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA IN RE: GUANTANAMO BAY DETAINEE LITIGATION 1 ) ) Misc. No. 08-442 (TFH) ) ) Civil Action No. 05-C V-2104(RBW) ) Unopposed Motion for Extension of Time to Respond to Motion For Leave to Amend Factual Return Petitioner Othman Ali Mohammed A1 Shamrany (ISN 171) respectfully requests a two week extension of the time to respond to Respondents' September 26,2008 Motion for Leave to Amend Factual Return. The current due date for Petitioner's response is Monday, October 6. If this motion is granted, the new deadline will be Monday, October 20. Counsel for Respondents have indicated that Respondents do not oppose this request. The reasons for the relief sought are as follows: 1. On September 26, 2008, Respondents filed their Motion For Leave To Amend Mr. Sharnrany's factual return and their Notice of Filing of the proposed amended factual return for Mr. Shamrany at the Guantanamo litigation secure facility. 2. In order to effectively respond to this motion, Petitioner's counsel must visit the secure facility in the Washington, DC area to review the proposed amendment, conduct any necessary legal research and analysis, and draft Petitioner's response. 3. Due to other pressing work commitments, lead counsel for Petitioner, who is based in New York, will be unable to travel to the secure facility until later this week, and more than one visit to review the proposed amendment likely will be required. Dockets.Justia.com 4. this motion. Accordingly, Petitioner requests a two-week extension of the time to respond to For all of these reasons, Petitioner requests that the Court grant this motion and set a new deadline of October 20,2008 for filing Petitioner's response to Respondents' motion. Dated: October 1, 2008 Respectfully submitted, weslek R. Powell wpow~ll@hunton.com HUNTON & WILLIAMS LLP 200 Park Avenue New York, NY 10166 (212) 309-1000 (2 12) 309- 1100 (facsimile) Karma B. Brown (Bar No. 479744) kbbrown@hunton.com HUNTON & WILLIAMS LLP 1900 K Street, N.W. Washington, DC 20006 (202) 955-1500 (202) 778-2201 (facsimile) Attorneys for Petitioner 99997.027530 EMF-US 26295226~1

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