Jabbarov et al vs. Bush et al

MOTION for Extension of Time to File Response/Reply to Respondent's Motion for Procedures Related to Review of Certain Detainee Materials

D.D.C.July 21, 2006

Approved for Public Filing by CSO IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ____________________________________ ) SEED FARHA, ) also listed as SAID ALI AL FARHA; ) ) MOHSEN, ) also listed as MUSHIN MUHAMMAD ) MUSHEEN MOQBILL; ) ) FAHD AL HARAAZI, ) also listed as FAHED ALI HARAZI; ) ) JABIR AL QUATANY, ) also listed as JABIR HASAN ) MUHAMED AL QAHTANI; ) ) Sami Muhyideen, ) as Next Friend of Mr. Farha ) and Mr. Mohsen; ) ) Jamal Kiyemba, ) as Next Friend of Mr. Haraazi ) and Mr. Al Quatany; ) ) Usama Hasan Abu Kabir, ) as Next Friend of Mr. Al Quatany; ) ) Petitioners, ) ) v. ) CIVIL ACTION NO. 05-CV-02386 (RBW) ) GEORGE W. BUSH, et al., ) ) Respondents. ) _________________________________) Case 1:05-cv-02386-UNA Document 98 Filed 07/21/2006 Page 1 of 3 2 MOTION FOR ENLARGEMENT OF TIME FOR PETITIONERS’ RESPONSE TO RESPONDENT’S MOTION FOR PROCEDURES RELATED TO REVIEW OF CERTAIN DETAINEE MATERIALS Petitioners respectfully request an enlargement of time under Federal Rule of Civil Procedure 6(b)(1) to September 30, 2006, to respond to Respondents’ Motion. See Fed. R. Civ. Proc. 6(b)(1) (discussing the court’s broad power to grant enlargements of time in cases where documents can or must be filed within a certain date if the request is made before the expiration of the period originally prescribed). Respondents filed a motion on July 7, 2006, seeking special procedures with respect to detainee materials and expedited briefing on this subject. This motion raises important concerns regarding the attorney-client privilege and detainees’ access to counsel. Petitioners have not had an opportunity to meet with counsel to discuss the ramifications of this motion on their cases. Counsel for petitioners are currently awaiting approval of their security clearances. Without these clearances, counsel cannot schedule a trip to Guantanamo Bay Naval Station to consult with Petitioners. The uncertain nature of the clearance approval process makes it difficult for counsel to anticipate a precise date by which they will receive their security clearances and be able to schedule a visit with Petitioners. Counsel for Petitioners fully intend to consult with Petitioners regarding this important issue as expeditiously as possible. Petitioners therefore request an enlargement of time until Case 1:05-cv-02386-UNA Document 98 Filed 07/21/2006 Page 2 of 3 3 September 30, 2006, to respond to Respondents’ motion. See Proposed Order, attached herein. Dated: July 21, 2006 Respectfully submitted, Counsel for Petitioner: /s/ Kit A. Pierson Brent N. Rushforth Kit A. Pierson Stuart M. Rennert Sarah B. Pojanowski Jenny L. Workman HELLER EHRMAN LLP 1717 Rhode Island Avenue, NW Washington, D.C. 20036 Tel: (202) 912-2000 Fax: (202) 912-2020 Case 1:05-cv-02386-UNA Document 98 Filed 07/21/2006 Page 3 of 3