Electronic Frontier Foundation v. Department of Justice

MOTION for Extension of Time to File Response/Reply to Defendant DOJ's Open America Stay Motion

D.D.C.March 8, 2007

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ELECTRONIC FRONTIER FOUNDATION ) ) Plaintiff, ) ) v. ) C.A. No. 06-1708 (CKK) ) DEPARTMENT OF JUSTICE ) ) Defendant. ) ) PLAINTIFF’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE Plaintiff Electronic Frontier Foundation respectfully moves, pursuant to Fed. R. Civ. P. 6(b), for an extension of time to March 14, 2007 in which to file its response to Defendant’s motion for an Open America stay. Plaintiff also asks that Defendant’s reply deadline be reset accordingly to April 5, 2007. Plaintiff’s response is currently due to be filed on March 9, 2007, and Defendant’s reply by March 30, 2007. Plaintiff requests this extension because of the unanticipated press of other business and counsel’s need to confer with colleagues at greater length than has been possible to date. Counsel for Defendant, Ms. Phillips, has indicated that Defendant does not oppose this motion. Respectfully submitted, /s/ Marcia Hofmann MARCIA HOFMANN D.C. Bar No. 484136 Case 1:06-cv-01708-CKK Document 9 Filed 03/08/2007 Page 1 of 2 2 DAVID L. SOBEL D.C. Bar No. 360418 ELECTRONIC FRONTIER FOUNDATION 1875 Connecticut Avenue NW Suite 650 Washington, DC 20009 (202) 797-9009 Counsel for Plaintiff Case 1:06-cv-01708-CKK Document 9 Filed 03/08/2007 Page 2 of 2