AL-ZAHRANI v. DONALD RUMSFELD, et al

Filing 307

AL-ZAHRANI v. DONALD RUMSFELD, et al

Doc. 307

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA _________________________________________ ) TOBIN DANA JACOBROWN, ) ) Plaintiff, ) ) Case No. 1:09-cv-01420 (RMU) v. ) ) ) ERNEST E. GARCIA, ) UNITED STATES OF AMERICA, ) ) Defendants. ) _________________________________________ ) DEFENDANTS' CONSENTED-TO MOTION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT Pursuant to Federal Rule of Civil Procedure 6(b) Ernest E. Garcia and the United States of America ("Defendants") respectfully request that the time for Defendants to answer or otherwise respond to the Complaint be extended by fourteen days from November 10, 2009 to November 24, 2009. This is the fourth extension requested for this deadline. In support of this Motion, counsel for Defendants states that, in their ongoing discussions, counsel for Defendants and counsel for Plaintiff have begun a process that may resolve the matter. As part of this process, counsel for Plaintiffs and Defendants have exchanged draft language and now need more time to make suggestions and have additional dialog. The additional time will not prejudice Plaintiff. Because no other deadlines have yet been set in this matter, the extension will not have an effect on other deadlines. Plaintiff consents to this motion. Based upon the forgoing, Defendants respectfully request that the Court grant the motion to extend time.

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Respectfully submitted, TONY WEST Assistant Attorney General CHANNING D. PHILLIPS Acting United States Attorney VINCENT M. GARVEY Deputy Director Civil Division /s/Bryan R. Diederich Bryan R. Diederich (MA BBO # 647632, NY Reg. # 4216164) Trial Attorney United States Department of Justice Civil Division, Federal Programs Branch P.O. Box 883, Room 7109 Washington, D.C. 20530 Tel: [phone] Fax: [phone] E-mail: [e-mail] Dated: November 5, 2009 Attorneys for Defendants