Center for Constitutional Rights v. United States Department of Defense et al

Filing 25

ORDER granting 24 Letter Motion for Extension of Time to File. Application granted. (Signed by Judge Naomi Reice Buchwald on 2/5/2024) (rro)

Case 1:23-cv-07689-NRB Document 24 Filed 02/02/24 Page 1 of 2
U.S. Department of Justice
[Type text]
United States Attorney
Southern District of New York
86 Chambers Street
New York, New York 10007

February 2, 2024

By ECF
The Honorable Naomi Reice Buchwald
United States District Judge
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312
Re:

Center for Constitutional Rights v. United States Department of Defense et al.,
23 Civ. 7689 (NRB)

Dear Judge Buchwald:
This Office represents the United States Department of Defense (“DOD”), the United
States Department of State (“DOS”), and the United States Department of Homeland Security
(“DHS”) (collectively, the “Government”), defendants in this action brought pursuant to the
Freedom of Information Act, 5 U.S.C. § 552 (“FOIA”). This case concerns a FOIA request
submitted by Plaintiff to DOD, DOS, and DHS pertaining to specific locations where Plaintiff
alleges the United States transferred and detained Afghan evacuees (the “FOIA Request”) and
seeking records related to alleged transfers, detentions, and locations.
We write jointly with Plaintiff’s counsel to request a four-day extension of the parties’
deadline to submit a joint status report, from Monday, February 12, 2024, to Friday, February 16,
2024. The parties are actively engaged in meeting and conferring on the processing of this FOIA
Request and have a meet and confer scheduled for February 12, 2024. The requested extension
would allow the parties to meet and confer on February 12, 2024, and provide the Court with the
most up-to-date information on the status of this case. This is the parties’ first request for an
extension of the deadline to submit a joint status report.
We thank the Court for its attention to this matter.
Respectfully,
DAMIAN WILLIAMS
United States Attorney for the
Southern District of New York
By:

/s/ Elizabeth J. Kim
ELIZABETH J. KIM
Assistant United States Attorney
Tel.: [phone]

Case 1:23-cv-07689-NRB Document 24 Filed 02/02/24 Page 2 of 2

Email: [e-mail]
Counsel for DOD, DOS, and DHS
Application granted.

Dated: February 5, 2024
New York, NY

/s/ Sadaf Doost
SADAF DOOST
J. WELLS DIXON
BAHER AZMY
Center for Constitutional Rights
666 Broadway, 7th Floor
New York, NY 10012
[phone]
[e-mail]
/s/ Christopher Godshall-Bennett
CHRISTOPHER GODSHALL-BENNETT
Muslim Advocates
P.O. Box 34440
Washington, D.C. 20043
[phone]
[e-mail]
Counsel for Plaintiff

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