Filing 867

Unopposed MOTION for Extension of Time to File Response/Reply as to (770 in 1:08-mc-00442-TFH, 91 in 1:05-cv-01607-RMU) MOTION to Amend/Correct Factual Return, (93 in 1:05-cv-01607-RMU, 803 in 1:08-mc-00442-TFH) MOTION to Amend/Correct Factual Returns by ABDUL RAHEEM GHULAM RABBANI, AHMMED GHULAM RABBANI (Attachments: # 1 Text of Proposed Order)(Handley, Matthew)

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IN RE: GUANTANAMO BAY DETAINEE LITIGATION Doc. 867 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA IN RE: GUANTANAMO BAY DETAINEE LITIGATION Misc. No. 08-442 (TFH) Civil Action No. 05-1607 (RMU) UNOPPOSED MOTION TO ENLARGE TIME FOR FILING A RESPONSE TO RESPONDENTS' MOTION FOR LEAVE TO FILE AMENDED FACTUAL RETURNS Abdul Raheem Ghulam Rabbani and Ahmmed Ghulam Rabbani ("Petitioners") hereby move for an enlargement of time to respond to Respondents' Motions for Leave to File Amended Factual Returns, which were filed on October 21, 2008 and October 24, 2008, respectively. Petitioners seek an enlargement of time of approximately two weeks, to and including November 18, 2008. This enlargement of time is necessary for Petitioners' counsel to have an opportunity to fully review and analyze the record in this action much of which is located at the secure facility in Virginia and properly respond to Respondents' motions. Pursuant to Local Civil Rule 7(m), undersigned counsel for Petitioners conferred with Respondents' counsel on October 23, 2008 and October 30, 2008. Respondents' counsel does not oppose this motion. A proposed order is attached hereto. Dated: October 30, 2008 ___/s/ Matthew Handley_____________ Michael D. Hausfeld Agnieszka M. Fryszman Matthew K. Handley Jason M. Leviton Matthew Kaplan COHEN MILSTEIN HAUSFELD & TOLL, P.L.L.C. 1100 New York, Ave., N.W. West Tower, Suite 500 Washington, D.C. 20005 Telephone: (202) 408-4600 Facsimile: (202) 408-4699 John Holland Anna Cayton-Holland LAW OFFICES OF JOHN HOLLAND 2150 W. 29th Ave., Suite 500 Denver, CO 80211 Telephone: (303) 860-1331 Facsimile: (303) 832-6506

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