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Full text of "gov.uscourts.dcd.116163"

Case 1:05-cv-01458-UNA-AK Documents Filed 1 1/17/2005 Page 1 of 8 



IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 



AHMED DOE, et al, 

Petitioners, 



GEORGE W. BUSH, 

President of the United States, 
et al.. 



Respondents. 



NABIL (Last Name Unknown), et al., 
Petitioners, 



GEORGE W. BUSH, 

President of the United States, 



Respondents. 



ABBAR SUFIAN AL HA WARY, et al.. 
Petitioners, 



GEORGE W. BUSH, 

President of the United States, 



Respondents. 



Civil Action No. 05-CV-1458 (ESH) 



Civil Action No. 05-CV-1504 (RMC) 



Civil Action No. 05-CV-1505 (RMC) 



Case 1:05-cv-01458-UNA-AK Documents Filed 1 1/17/2005 Page 2 of 8 



SHAFIIQ (Last Name Unknown), et al. 
Petitioners, 



GEORGE W. BUSH, 

President of the United States, 
et al. 



Respondents. 



SADAR DOE, et al, 

Petitioners, 



GEORGE W. BUSH, 

President of the United States, 



Respondents. 



MUHAMMED QASIM, et al, 
Petitioners, 



GEORGE W. BUSH, 

President of the United States, 



Respondents. 



Civil Action No. 05-CV-1506 (RMC) 



Civil Action No. 05-CV-1704 (JR) 



Civil Action No. 05-CV-1779 (JDB) 



PETITIONER'S UNOPPOSED MOTION TO EXTEND SHOW CAUSE BRIEFING DEADLINES 

Petitioners respectfully request that the briefing schedule set out in Judge Oberdorfer's 
November 4, 2005 Order to Show Cause (the "Order") be reset and in support thereof state as 
follows: 

1 . Under the Order, the Parties are required to do the following: 
1) Petitioners must show cause on or before Friday, November 18, 2005; 



Case 1:05-cv-01458-UNA-AK Documents Filed 1 1/17/2005 Page 3 of 8 



2) Respondents may respond by November 28, 2005; 3) a hearing is to be held on 
December 5, 2005; and 4) Petitioners and Respondents are to consult with Magistrate 
Judge Kay "as soon as is practicable (but in any event before the hearing) to discuss 
how counsel for Petitioners may obtain access to the detainees . . . ." Order at 4 - 5. 

2. On the evening of November 14, 2005, Respondents filed their Motion for 
Clarification or, in the Alternative, Reconsideration, of the Court's November 4, 2005 
Order to Show Cause ("Respondents' Motion for Clarification"). Respondents' Motion 
states, "respondents are unclear as to what the Court intended should be the scope of the 
parties' discussions with Magistrate Judge Kay" and explains that Respondents feel 
"there is no need for any consultation or discussion with Magistrate Judge Kay or 
otherwise on the subject of how counsel for petitioners may obtain special access to 
detainees . . . ." Respondents' Motion for Clarification at 1, 4-5. 

3. Petitioners will oppose Respondents' Motion for Clarification, which 
seeks a significant change in the Order. Petitioners wish to have the issue resolved 
before they are required to Show Cause. 

4. In accordance with Local Civil Rule 7(m), counsel for Petitioners 
conferred with counsel for the Respondents regarding this Motion and Respondents do 
not oppose it. 

5. Undersigned counsel has also conferred with counsel for all above-named 
Petitioners and has received authority to file this Motion on behalf of all Petitioners. 

WHEREFORE: Petitioners request that the Order's November 18, 2005 deadline 
to Show Cause and the November 28, 2005 deadline to respond be postponed until the 
Court has ruled on Respondents' Motion for Clarification. Petitioners request that the 



Case 1:05-cv-01458-UNA-AK Documents Filed 1 1/17/2005 Page4of8 

December 5, 2005 hearing be used to address Respondents' Motion for Clarification, to 
set a new schedule for briefing the Order and to address any other scheduling matters 
arising out of the Order. A proposed order is attached hereto. 
Dated: November 1 7, 2005 

Respectfully submitted, 



I si Kevin G. Boris 



Kevin G. Boris 

Louis A. Ruprecht 

RUPRECHT, HART & WEEKS, LLP 

306 Main Street 

Millburn, NJ 07041 

(973) 379-2446 

Of Counsel: 

Barbara Olshansky (NY0057) 

CENTER FOR CONSTITUTIONAL 

RIGHTS 

666 Broadway, 7th Floor 

New York, New York 10012 

Tel: (212) 614-6439 

Fax: (212) 614-6499 

Counsel for Petitioners Ahmed Doe and 
Omar Deghayes 



Case 1:05-cv-01458-UNA-AK Documents Filed 1 1/17/2005 Page 5 of 8 



CERTIFICATE OF SERVICE 

I certify that on November 17, 2005 I served a copy of the foregoing document to 
the following by Electronic Service 

Preeya Noronha, Esq. 

United Stated Department of Justice 

Civil Division, Federal Programs Branck 

20 Massachussetts Ave., N.W. Room 7144 

Washington, DC 20530 

preeva.noronha(a),usdoi.gov 

Elizabeth Gilson, Esq. 
egilsonfS.snet.net 

Gita Gutierrez, Esq. 
Ggutierrezfajccr-ny.org 

Danielle Voorhees, Esq. 
dvoorheestahollandhart.com 



Case 1:05-cv-01458-UNA-AK Documents Filed 1 1/17/2005 Page6of8 



IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 



AHMED DOE, et al, 

Petitioners, 



GEORGE W. BUSH, 

President of the United States, 
et al, 



Respondents. 



NABIL (Last Name Unknown), et al. 
Petitioners, 



GEORGE W. BUSH, 

President of the United States, 



Respondents. 



ABBAR SUFIAN AL HAWARY, et al, 
Petitioners, 



GEORGE W. BUSH, 

President of the United States, 



Respondents. 



Civil Action No. 05-CV-1458 (ESH) 



Civil Action No. 05-CV-1504 (RMC) 



Civil Action No. 05-CV-1505 (RMC) 



Case 1:05-cv-01458-UNA-AK Documents Filed 1 1/17/2005 Page 7 of 8 



SHAFIIQ (Last Name Unknown), et al 
Petitioners, 



GEORGE W. BUSH, 

President of the United States, 
et al, 



Respondents. 



SADAR DOE, et al, 

Petitioners, 



GEORGE W. BUSH, 

President of the United States, 



Respondents. 



MUHAMMED QASIM, et al, 
Petitioners, 



GEORGE W. BUSH, 

President of the United States, 



Respondents. 



Civil Action No. 05-CV-1506 (RMC) 



Civil Action No. 05-CV-1704 (JR) 



Civil Action No. 05-CV-1779 (JDB) 



ORDER (PROPOSED) 

Having considered Petitioners' Unopposed Motion to Extend Show Cause 
Briefing Deadlines, that Motion is GRANTED; and it is further 

ORDERED: that the November 18, 2005 deadline to Show Cause and the 
November 28, 2005 deadline to respond are hereby vacated. 



Case 1:05-cv-01458-UNA-AK Documents Filed 1 1/17/2005 Page8of8 



ORDERED: that a hearing will be held on Monday, December 5, 2005 to address 
Respondents' Motion for Clarification, to set a new Show Cause briefing schedule and 
to address any other scheduling matters arising out of the Order to Show Cause. 



Louis F. Oberdorfer 

UNITED STATES DISTRICT JUDGE