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