AL-ZAHRANI v. DONALD RUMSFELD, et al

Filing 10

Unopposed MOTION for Extension of Time to Answer or Otherwise Respond by UNITED STATES (Attachments: # 1 Text of Proposed Order)(Werner, Paul)

AL-ZAHRANI v. DONALD RUMSFELD, et al

Doc. 10

UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA ) ) Plaintiffs, ) ) v. ) ) Donald RUMSFELD, et al. ) ) and ) ) UNITED STATES, ) ) Defendants. ) ____________________________________) Talal AL-ZAHRANI, et al.,

Case No.: 1:09-CV-00028 (ESH)

UNITED STATES' UNOPPOSED MOTION FOR ENLARGEMENT OF TIME FOR DEFENDANTS TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFFS' AMENDED COMPLAINT Pursuant to Federal Rule of Civil Procedure 6(b)(1), the United States, by and through undersigned counsel, respectfully moves this Court for a thirty-day enlargement of time, up to and including June 26, 2009, for Defendants to answer or otherwise respond to Plaintiffs' Amended Complaint. In support of this motion, the United States asserts as follows: 1. Plaintiffs instituted this action with the filing of their Complaint on January 7, 2009. 2. Plaintiffs amended their Complaint on January 29, 2009. 3. Service was accomplished as to all Defendants no sooner than February 26, 2009. Thus, the original deadline for the Defendants' response to Plaintiffs' Amended Complaint was April 27, 2009. 4. The United States moved for a thirty-day enlargement of time on April 24, 2009. Plaintiffs notified the Court that they did not object to the United States' motion for an

Dockets.Justia.com

enlargement of time. 5. The Court granted the United States' motion for an enlargement of time on April 29, 2009, giving the Defendants until May 27, 2009 to respond to Plaintiffs' Amended Complaint. 6. Pursuant to Local Rule 7(m), the United States' counsel contacted Plaintiffs' counsel, Pardiss Kebriaei, on May 26, 2009 regarding the contents of this motion. Plaintiffs' counsel stated she did not oppose this motion. In addition, the United States and Plaintiffs are currently discussing an expanded briefing schedule that they would propose to the court. 7. This request is made in good faith and not for purposes of delay. 8. There are no other previously scheduled deadlines in this case. A proposed Order is attached.

Dated: May 26, 2009

Respectfully submitted,

TONY WEST Assistant Attorney General, Civil Division JEFFREY A. TAYLOR United States Attorney District of Columbia TIMOTHY P. GARREN Director, Torts Branch PHILIP D. MACWILLIAMS (D.C. Bar No. 482883) Trial Attorney, Torts Branch Civil Division U.S. Department of Justice P.O. Box 888 Benjamin Franklin Station Washington, DC 20044 [phone] [phone] (facsimile) /s/ Paul E. Werner PAUL E. WERNER (MD Bar, under LCvR 83.2(e)) Trial Attorney United States Department of Justice Torts Branch, Civil Division P.O. Box 7146 Ben Franklin Station Washington, DC 20044 [phone] (phone) [phone] Attorneys for the United States

CERTIFICATE OF SERVICE I hereby certify that on May 26, 2009, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system, which will send notification of such filing to the following:

Pardiss Kebriaei Shayana Kadidal CENTER FOR CONSTITUTIONAL RIGHTS 666 Broadway, 7th Floor New York, NY 10012 [e-mail] Counsel for Plaintiffs Meetali Jain International Human Rights Law Clinic American University WASHINGTON COLLEGE OF LAW 4801 Massachusetts Ave., NW Washington, DC 20016 [e-mail] Counsel for Plaintiffs

/s/ Paul E. Werner PAUL E. WERNER (MD Bar, under LCvR 83.2(e)) Trial Attorney United States Department of Justice Torts Branch, Civil Division P.O. Box 7146 Ben Franklin Station Washington, DC 20044 [phone] (phone)