ELECTRONIC PRIVACY INFORMATION CENTER v. FEDERAL TRADE COMMISSION

Filing 6

Consent MOTION for Extension of Time to File Answer re 1 Complaint or Otherwise Respond to 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 extension of
thirty days of the current deadline for it 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 July 14, 2011, FTC’s answer is currently due July 29, 2011. EPA
requests a new deadline of Monday, August 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 nearing agreement on a settlement of the case. Counsel have largely come to
agreement on the substance of the terms of a settlement, and need only work out a few details,
including the wording of a settlement stipulation. Although counsel anticipates that this will go
smoothly, undersigned counsel will be out of the office for two weeks starting next week, and
will need time upon returning to the office to catch up with other accumulated work in other
cases. Accordingly, the FTC respectfully requests 30 additional days of the current deadline.
This is the FTC’s third request to extend this deadline. A proposed order is attached.

July 28, 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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