SOGHOIAN v. DEPARTMENT OF JUSTICE

Filing 14

Consent MOTION for Extension of Time to Amend 12 Scheduling Order,, Consent MOTION for Extension of Time to File Motion for Summary Judgment by DEPARTMENT OF JUSTICE (Attachments: # 1 Text of Proposed Order)(Interrante, John)

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

CHRISTOPHER SOGHOIAN,
Plaintiff,
v.
DEPARTMENT OF JUSTICE,
Defendant.

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Civil Action No. 11-1080 (ABJ)
ECF

DEFENDANT’S CONSENT MOTION FOR ENLARGEMENT OF TIME
TO FILE MOTION FOR SUMMARY JUDGMENT AND TO AMEND
THE COURT’S OCTOBER 11, 2011 SCHEDULING ORDER
Defendant, United States Department of Justice, by and through its undersigned counsel,
respectfully moves this Court pursuant to Federal Rule of Civil Procedure 6(b)(1) for an enlargement
of time of 17 days to, and including, February 6, 2012, in which to file a motion for summary
judgment in this case, which arises under the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552,
as amended. Defendant’s motion is due by January 20, 2012, pursuant to the Court’s Scheduling
Order dated October 11, 2011 (ECF No. 12). This is defendant’s first request for an enlargement
of time of this deadline. Pursuant to Local Rule 7(m), undersigned counsel has conferred with
plaintiff, who is proceeding pro se, and plaintiff consents to the requested extension on the condition
that plaintiff’s opposition deadline is adjusted by 17 days. The parties further agree that defendant’s
reply will be due in 14 days rather the 21 days set in the initial scheduling order. A proposed order
granting this motion is attached.
There is good cause to grant this motion. Undersigned counsel requires additional time to
review the Vaughn declarations and indices submitted by the DOJ components that have processed
records in response to plaintiff’s FOIA request and to draft and file a motion for summary judgment.

This time is required due to the press of other business during the initial period set by the Court for
filing the dispositive motion. Specifically, undersigned counsel completed a two-week trial in Gold
v. Gensler, Civil Action No. 09-2125 (RLW), on December 16, 2012, was on committed use-or-lose
leave from December 19, 2011-January 2, 2012, and was required to travel to Charleston, South
Carolina for depositions in Reed v. Department of Navy, Civil Action No. 10-1160 (ESH), on
January 9-10, 2012. Additional depositions have been scheduled in the Reed case in Charleston on
January 18-19, 2012 and in Washington, D.C. on February 1-3, 2012.
WHEREFORE, Defendant respectfully requests an enlargement of time of 17 days to file
a motion for summary judgment and that the Court entered the proposed Order amending the
October 11, 2011 Scheduling Order as agreed by the parties.
Respectfully submitted,
RONALD C. MACHEN JR, DC Bar # 447889
United States Attorney for the District of Columbia
RUDOLPH CONTRERAS, D.C. Bar # 434122
Chief, Civil Division
By:

/s/
JOHN G. INTERRANTE
PA Bar # 61373
Assistant United States Attorney
Civil Division
555 4th Street, N.W., Room E-4808
Washington, D.C. 20530
Tel:
202.514.7220
Fax: [phone]
Email: [e-mail]

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