Public Employees for Environmental Responsibility v. National Park Service

MOTION for Extension of Time to File Answer

D.D.C.November 22, 2013

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA __________________________________________ ) PUBLIC EMPLOYEES FOR ENVTL. ) RESPONSIBILITY, ) ) Plaintiff, ) ) v. ) Civil Action No. 13-1414 (ESH) ) NATIONAL PARK SERVICE, ) ) Defendant. ) __________________________________________) DEFENDANT’S CONSENT MOTION FOR AN EXTENSION OF TIME Defendant respectfully requests that the Court extend the time for Defendant to respond to the Complaint (ECF No. 1) by another 45 days. See Fed. R. Civ. P. 6(b)(1)(A). Specifically, Defendant requests that the deadline be extended from December 5, 2013, to January 17, 2014. Plaintiff’s counsel consented to this second extension by telephone on November 20, 2013. There is good cause for the Court to grant this motion. Plaintiff brought this action under the Freedom of Information Act (FOIA), 5 U.S.C. § 552, largely challenging the adequacy of Defendant’s search for records. In response to the Complaint and discussions with Plaintiff, Defendant is conducting additional searches and has begun producing records to Plaintiff, including records created after the Complaint was filed. The additional time will allow Defendant to continue these efforts and to gather sufficient information about the responsive records to provide a production schedule. Accordingly, Defendant respectfully requests that the Court extend the time to respond to the Complaint until and including January 17, 2014. A proposed order is attached. Case 1:13-cv-01414-ESH Document 6 Filed 11/22/13 Page 1 of 2 2 Dated: November 22, 2013. Respectfully submitted, RONALD C. MACHEN JR., D.C. Bar # 447889 United States Attorney DANIEL F. VAN HORN, D.C. Bar #924092 Chief, Civil Division By: /s/ Kevin Laden Kevin Laden, Va. State Bar # 48478 Special Assistant United States Attorney 555 4 th Street, N.W., E-4916 Washington, D.C. 20530 Tel: (202) 252-2569 kevin.laden@usdoj.gov Case 1:13-cv-01414-ESH Document 6 Filed 11/22/13 Page 2 of 2