SOGHOIAN v. DEPARTMENT OF JUSTICE

Filing 7

Consent MOTION for Extension of Time to File Answer re 1 Complaint 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 ANSWER OR OTHERWISE RESPOND TO COMPLAINT
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 30 days to, and including, August 12, 2011, in which to file an answer or otherwise
respond to the complaint in this case (ECF No. 1), which arises under the Freedom of Information
Act (“FOIA”), 5 U.S.C. § 552, as amended. Defendant’s response to the FOIA complaint is due
within 30 days of service or by July 14, 2011. This is defendant’s first request for an enlargement
of time in this case. Pursuant to Local Rule 7(m), undersigned counsel has conferred with plaintiff,
who is proceeding pro se, and plaintiff consents to the requested extension. A proposed order
granting this motion is attached.
There is good cause to grant this motion. Undersigned counsel, who has been recently
assigned to this case, requires additional time to review the allegations in the complaint and draft
an answer. Counsel also requires additional time to confer and consult with the two agency
components that have produced records in response to Plaintiff’s FOIA request subject to
withholdings under FOIA exemptions.

WHEREFORE, Defendant respectfully requests an enlargement of time of 30 days to file
an answer or otherwise respond to the complaint.
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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