IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 976

Consent MOTION to Stay by MAHMOAD ABDAH, JAMAL MAR'I, SALMAN YAHALDI HSAN MOHAMMED SAUD (Attachments: # 1 Text of Proposed Order)(Livingston, Schuyler)

IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Doc. 976

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ______________________________ IN RE: GUANTANAMO BAY DETAINEE LITIGATION ) ) ) ) ) Misc. No. 08-0442 (TFH) Civil Action No. 04-1254 (HHK)

CONSENT MOTION FOR STAY OF PROCEEDINGS Petitioners Mahmoad Abdah (ISN 31), Salman Yahaldi Hsan Mohammed Saud (ISN 508), and Jamal Mar'i (ISN 577) seek an indefinite stay of all proceedings in their individual habeas matters. Respondents do not object to the Motion. Petitioners and Respondents agree that the obligations of both the movants and the Government under Judge Hogan's November 6, 2008 Case Management Order should be suspended with respect to these three Petitioners unless and until the stay is lifted, and that either party may seek to lift the stay for any reason in the future. They also agree that during the pendency of the stay the Protective Order and 30-Day Notice Order already entered in Abdah v. Bush, 04-CV1254 (HHK), will remain operative with respect to these three Petitioners. The remaining Petitioners in Abdah do not seek a stay of the proceedings. Dated: November 13, 2008 Washington, D.C. Respectfully submitted,

S. William Livingston D.C. Bar. No. 59005 Alan A. Pemberton D.C. Bar. No. 367108 COVINGTON & BURLING LLP

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1201 Pennsylvania Ave., N.W. Washington, DC 20004-2401 [phone] (phone) [phone] (fax) [e-mail] [e-mail] 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 347-564-5043 (cell) 815-753-9301 [e-mail] Attorneys for Petitioner