Al Shimari v. Dugan et al

Filing 77

MOTION for Leave to File Supplemental Memorandum in Support of Motion to Dismiss Amended Complaint by CACI International, Inc, CACI Premier Technology, Inc. (Attachments: # 1 Exhibit 1)(Koegel, Joseph)

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA ALEXANDRIA DIVISION ____________________________________ SUHAIL NAJIM ABDULLAH AL SHIMARI, et al., Plaintiffs, v. CACI INTERNATIONAL INC, et ano., Defendants. ) ) ) ) ) ) ) ) ) ) ) )

No. 1:08-CV-827-GBL-JFA

MOTION OF DEFENDANTS CACI INTERNATIONAL INC AND CACI PREMIER TECHNOLOGY, INC., FOR LEAVE TO FILE SUPPLEMENTAL MEMORANDUM IN SUPPORT OF THEIR MOTION TO DISMISS PLAINTIFFS' AMENDED COMPLAINT
Defendants CACI International Inc and CACI Premier Technology, Inc. (collectively, "CACI") respectfully seek leave to file a supplemental memorandum, attached hereto as Exhibit 1, in support of their motion to dismiss Plaintiffs' Amended Complaint. The supplemental memorandum would address the newly-released Senate Armed Services Committee "Inquiry into the Treatment of Detainees in U.S. Custody" and its impact on CACI's assertion that Plaintiffs' claims present nonjusticiable political questions. See Koegel Decl., Ex. A (the

"Report"). The bases for CACI's motion are set forth in greater detail in the accompanying memorandum. Wherefore, CACI respectfully requests that the Court grant it leave to file the supplemental memorandum attached as Exhibit 1. A proposed order is attached.

Respectfully submitted, /s/ J. William Koegel, Jr. J. William Koegel, Jr. Virginia Bar No. 38243 John F. O'Connor (admitted pro hac vice) Attorneys for Defendants CACI Premier Technology, Inc. and CACI International Inc STEPTOE & JOHNSON LLP 1330 Connecticut Avenue, N.W. Washington, D.C. 20036 [phone] - telephone [phone] ­ facsimile [e-mail] [e-mail] December 19, 2008

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CERTIFICATE OF SERVICE I hereby certify that on the 19th day of December, 2008, I will electronically file the foregoing with the Clerk of Court using the CM/ECF system, which will then send a notification of such filing (NEF) to the following: Susan L. Burke William Gould Attorneys for Plaintiff Burke O'Neil LLC 4112 Station Street Philadelphia, PA 19127 [phone] ­ telephone [e-mail] [e-mail]

/s/ J. William Koegel, Jr. J. William Koegel, Jr. Virginia Bar No. 38243 Attorney for Defendant CACI-Athena, Inc. STEPTOE & JOHNSON LLP 1330 Connecticut Avenue, N.W. Washington, D.C. 20036 [phone] - telephone [phone] ­ facsimile [e-mail]