ELECTRONIC PRIVACY INFORMATION CENTER v. FEDERAL TRADE COMMISSION

Filing 5

Consent MOTION for Extension of Time to File Answer re 1 Complaint by FEDERAL TRADE COMMISSION (Attachments: # 1 Text of Proposed Order)(Burch, Alan)

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

ELECTRONIC PRIVACY INFORMATION CENTER,
Plaintiff,
v.
FEDERAL TRADE COMMISSION,
Defendant.

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Civil Action No.: 11-0881 (HHK)

CONSENT MOTION TO ENLARGE TIME TO FILE ANSWER
OR OTHERWISE RESPOND TO COMPLAINT
Defendant, the Federal Trade Commission (“FTC”), respectfully requests an additional
fourteen days to file an answer or otherwise respond to the complaint in this case. This case
arises under the Freedom of Information Act (“FOIA”). Pursuant to the Court’s Minute Order of
June 10, 2011, FTC’s answer is currently due July 15, 2011. EPA requests a new deadline of
July 29, 2011. Counsel for Plaintiff consents to this motion.
Good cause exists for the Court to extend the deadline under Rule 6(b)(1)(A) because the
parties are actively exploring a possible settlement of the case. Counsel for the parties met faceto-face this week and, as part of their ongoing discussion, agreed that it made sense to ask the
Court to delay the deadline for FTC to file its answer, in the hopes that a final agreement could
be reached to resolve the case.
This is the FTC’s second request to extend this deadline. A proposed order is attached.

July 14, 2011

Respectfully submitted,
RONALD C. MACHEN JR., D.C. Bar #447889
United States Attorney
for the District of Columbia
RUDOLPH CONTRERAS, D.C. Bar # 434122
Chief, Civil Division
By: /s/
ALAN BURCH, D.C. Bar # 470655
Assistant United States Attorney
555 4th St., N.W.
Washington, D.C. 20530
[phone], [e-mail]

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