HARRIS et al v. SOCIALIST PEOPLE'S LIBYAN ARAB JAMAHIRIYA et al

MOTION to Substitute Counsel and Enlarge Time

D.D.C.March 14, 2008

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA _______________________________________ ) KARIN GERTRUDE HARRIS, et al., ) ) Plaintiffs, ) ) v. ) 1:06-cv-00732-RWR ) SOCIALIST PEOPLE’S LIBYAN ARAB ) JAMAHIRYA, et al., ) ) Defendants. ) _______________________________________) SOCIALIST PEOPLE’S LIBYAN ARAB JAMAHIRIYA AND JAMAHIRIYA SECURITY ORGANIZATION’S CONSENT MOTION TO SUBSTITUTE COUNSEL AND FOR ENLARGEMENTS OF TIME Defendants Socialist People’s Libyan Arab Jamahiriya and Jamahiriya Security Organization (collectively “Libya”) respectfully move this Court, pursuant to Fed. R. Civ. P. 6(b), for permission to substitute their attorney of record in this matter and enlarge Libya’s times to respond to the Amended Complaint and Plaintiffs’ Motion for Partial Summary Judgment on Liability, and state as follows: 1. Libya seeks permission to substitute Christopher M. Curran, Francis A. Vasquez Jr., and Nicole E. Erb, of the firm of White & Case LLP, in place of Arman Dabiri, who is presently the attorney of record for Libya in this action. 2. Libya believes that a new litigation approach in the United States is urgently required and a new approach will serve to further the great strides its country has taken, and continues to take, to rebuild its relations with the United States over the past five years. Case 1:06-cv-00732-RWR Document 38 Filed 03/14/2008 Page 1 of 4 2 3. In view of the engagement of new counsel, Libya further respectfully requests that the Court enlarge Libya’s time to respond to Plaintiffs’ Amended Complaint. On March 3, 2008, the Court ruled that Plaintiffs had the right to file an Amended Complaint as a matter of course. (Docket No. 32). Accordingly, Libya’s response is due March 17, 2008. Libya respectfully requests that it be permitted to file its response by May 1, 2008. 4. This enlargement of time is warranted to allow new counsel sufficient time to become familiar with this complex matter, accommodate the logistical challenges inherent in coordinating the defense of this matter with parties located outside the United States, and to adequately brief this matter to fully inform the Court’s analysis. This is Libya’s first request for an enlargement of time regarding the Amended Complaint. No party will be prejudiced by the relief requested. 5. Further, on March 12, 2008, Plaintiffs filed a Motion for Partial Summary Judgment as to Liability. (Docket No. 34). For the same reasons stated above, Libya respectfully requests that its deadline to respond to this Motion be extended from March 24, 2008 to May 8, 2008. 6. Pursuant to Local Civil Rule 7(m), the undersigned hereby certify that they have conferred with Plaintiffs’ lead counsel, Steven R. Perles, in an effort to obtain his consent for the requested enlargements of time. Mr. Perles does not consent to the relief requested and has indicated that he intends to file an opposition on or about March 17, 2008. WHEREFORE, the Socialist People’s Libyan Arab Jamahiriya and the Jamahiriya Security Organization respectfully request that the Court grant: (1) their Motion to Substitute Counsel, (2) Extend their time to respond to the Amended Complaint to May 1, 2008, and (3) Case 1:06-cv-00732-RWR Document 38 Filed 03/14/2008 Page 2 of 4 3 Extend their time to respond to Plaintiffs’ Motion for Partial Summary Judgment as to Liability to May 8, 2008. A proposed order is attached. Dated: March 14, 2008 Respectfully submitted, /s/ Arman Dabiri Arman Dabiri (D.C. Bar. # 563351) Law Offices of Arman Dabiri & Associates, P.L.L.C. 1725 I St., N.W. Suite 300 Washington, DC 20006 Tel.: (202) 349-3893 E-mail: armandab@worldnet.att.net Counsel of Record for Socialist People’s Libyan Arab Jamahiriya and Jamahiriya Security Organization /s/ Christopher M. Curran Christopher M. Curran (D.C. Bar No. 408561) Francis A. Vasquez, Jr.(D.C. Bar No. 442161) Nicole E. Erb (D.C. Bar No. 466620) 701 Thirteenth Street, N.W. Washington, DC 20005 Tel.: (202) 626-3600 Fax: (202) 639-9355 Substitute Counsel for Socialist People’s Libyan Arab Jamahiriya and Jamahiriya Security Organization Case 1:06-cv-00732-RWR Document 38 Filed 03/14/2008 Page 3 of 4 CERTIFICATE OF SERVICE I hereby certify that on March 14, 2008, a copy of the foregoing Consent Motion To Substitute Counsel And For Enlargements Of Time and Proposed Order was served upon the following parties via the Electronic Case Filing (“ECF”) system: Steven R. Perles The Perles Law Firm, PC 1146 19th Street, N.W., Fifth Floor Washington, DC 20036 Counsel for Plaintiffs /s/ Christopher M. Curran Case 1:06-cv-00732-RWR Document 38 Filed 03/14/2008 Page 4 of 4