AL-AULAQI v. OBAMA et al

Filing 7

Consent MOTION for Extension of Time to File an Opposition to Plaintiff's Motion for a Preliminary Injunction and for Entry of an Order Setting Forth Deadlines by ROBERT M. GATES, BARACK H. OBAMA, LEON C. PANETTA (Attachments: # 1 Text of Proposed Order)(Leary, Peter)

AL-AULAQI v. OBAMA et al

Doc. 7

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA __________________________________________ ) NASSER AL-AULAQI, ) ) Plaintiff, ) ) Civil Action No. 1:10-cv-1469 (JDB) v. ) ) BARACK H. OBAMA, et al., ) ) Defendants. ) __________________________________________) CONSENT MOTION FOR AN EXTENSION OF TIME AND FOR ENTRY OF AN ORDER SETTING FORTH DEADLINES Defendants Barack H. Obama, President of the United States, Leon E. Panetta, Director of the Central Intelligence, and Robert M. Gates, Secretary of Defense, pursuant to Rule 6(b)(1)(A) of the Federal Rules of Civil Procedure, hereby move with the consent of Plaintiff for an extension of time for Defendants to file an opposition to the Plaintiff's Motion for Preliminary Injunction (Dkt. No. 3). Pursuant to LCvR 65.1(c), Defendants' opposition is currently due on Tuesday, September 7, 2010.1 Defendants respectfully request that this Court grant Defendants an extension of time of eight (8) calendar days until Wednesday, September 15, 2010 in order to address the significant matters raised by the motion. The undersigned counsel for the parties have conferred regarding Defendants' request for an extension of time, and Plaintiff's counsel consents to this request. In addition, the parties have agreed that, if Defendants' request for an extension of time is
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Seven days from August 30, 2010--when Plaintiff's Motion for Preliminary Injunction was filed--is September 6, 2010, which is a legal holiday. Pursuant to Federal Rule of Civil Procedure 6(a)(1)(C), Defendants' opposition would be due the next day. 1

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granted, the Plaintiff be granted until Wednesday, September 22, 2010, to file a reply. WHEREFORE, the parties respectfully request that the Court enter the attached order setting forth the aforementioned deadlines for Defendants' Opposition to Plaintiff's Motion for a Preliminary Injunction and Plaintiff's Reply. Respectfully submitted this 1st day of September, 2010.

/s/ Arthur B. Spitzer (D.C. Bar 235960) American Civil Liberties Union of the National Capital Area 1400 20th Street, N.W., Suite 119 Washington, DC 20036 Phone: [phone] Fax: [phone] [e-mail]

TONY WEST Assistant Attorney General, Civil Division RONALD C. MACHEN, Jr. United States Attorney JOSEPH H. HUNT Director, Federal Programs Branch VINCENT M. GARVEY Deputy Director, Federal Programs Branch /s/ Peter D. Leary (VA Bar 71196) Trial Attorney, Federal Programs Branch Anthony J. Coppolino Special Litigation Counsel U.S. Department of Justice, Civil Division Tel: [phone] Fax: [phone] [e-mail] Mailing Address: Post Office Box 883 Washington, D.C. 20044 Courier Address: 20 Massachusetts Ave., NW, Rm. 6102 Washington, D.C. 20001 Counsel for Defendants

Jameel Jaffer Ben Wizner Jonathan M. Manes American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Phone: [phone] [e-mail]

Pardiss Kebriaei Maria C. LaHood William Quigley Center for Constitutional Rights 666 Broadway, 7th Floor New York, NY 10012 Phone: [phone] [e-mail] Counsel for Plaintiff

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