IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Filing 977

Consent MOTION to Stay by FATIMA NASSER YAHIA ABDULLAH KHUSSROF, MOHAMMED NASSER YAHIA ABDULLAH KHUSSROF (Attachments: # 1 Text of Proposed Order)(Livingston, Schuyler)

IN RE: GUANTANAMO BAY DETAINEE LITIGATION

Doc. 977

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ______________________________ IN RE: GUANTANAMO BAY DETAINEE LITIGATION ) ) ) ) ) Misc. No. 08-0442 (TFH) Civil Action Nos. 05-1429 (RMU)

CONSENT MOTION FOR STAY OF PROCEEDINGS Petitioner Mohammed Nasser Yahia Khussrof (ISN 509) seeks an indefinite stay of all proceedings in his individual habeas matter. Respondents do not object to the Motion. Petitioner and Respondents agree that the obligations of both the movant and the Government under Judge Hogan's November 6, 2008 Case Management Order and Judge Urbina's November 10, 2008 Supplemental Case Management Order should be suspended with respect to Mr. Khussrof 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 Hatim v. Bush, 05-CV-1429 (RMU), will remain operative with respect to Mr. Khussrof. The remaining Petitioner in Hatim does 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