SOGHOIAN v. DEPARTMENT OF JUSTICE

Filing 16

Consent MOTION for Extension of Time to Amend January 19, 2012 Minute Order by CHRISTOPHER SOGHOIAN (Attachments: # 1 Text of Proposed Order)(SOGHOIAN, CHRISTOPHER)

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

________________________________
CHRISTOPHER SOGHOIAN,
)
)
Plaintiff,
)
)
v.
)
)
DEPARTMENT OF JUSTICE
)
)
Defendant.
)
__________________________ ______ )

Civil Action No. 11-1080 (ABJ)
ECF

PLAINTIFF’S CONSENT MOTION FOR ENLARGEMENT OF TIME TO FILE A
MOTION IN OPPOSITION TO DEFENDANT’S MOTION FOR SUMMARY
JUDGMENT AND TO AMEND THE COURT’S JANUARY, 19 2012 MINUTE ORDER
Plaintiff, Christopher Soghoian, pro se, respectfully moves this Court pursuant to Federal Rule of
Civil Procedure 6(b)(1) for an enlargement of time of 31 days to, and including, April 9, 2012, in
which to file a motion in opposition to the defendant’s motion for summary judgment in this
case, which arises under the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, as amended.
Plaintiff’s motion is due by March 9, 2012, pursuant to the Court’s Minute Order dated January
19, 2012. This is plaintiff’s first request for an enlargement of time of this deadline.
Pursuant to Local Rule 7(m), plaintiff has conferred with defendant’s counsel, Mr. Interrante,
and defendant consents to the requested extension. As Mr. Interrante will be on leave the week of
April 9, 2012, defendant has requested an additional week to submit its reply. The plaintiff has
consented to this request. A proposed order granting this motion is attached.
There is good cause to grant this motion. Plaintiff is a pro se litigant and does not have a formal
education in the law. Other than two amicus briefs filed in surveillance related cases during the
past two years, plaintiff also has no experience litigating in the Federal Courts. Plaintiff thus
requires additional time to become acquainted with the FOIA litigation process and to prepare
his response.
WHEREFORE, Plaintiff respectfully requests an enlargement of time of 31 days to file a motion
in opposition to the defendant’s motion for summary judgment and that the Court enter the
proposed Order amending the January 19, 2012 Minute Order as agreed by the parties.

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Respectfully submitted,
/s/
__________________________________
CHRISTOPHER SOGHOIAN
(pro se)
1725 Irving St NW
Washington, DC 20010
Tel: [phone]
Email: [e-mail]

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