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Jill Kelley Govt Extension 7-29-13

Jill Kelley Govt Extension 7-29-13

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Published by Kristal Roberts
DEFENDANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER
OR OTHERWISE RESPOND TO THE COMPLAINT
DEFENDANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER
OR OTHERWISE RESPOND TO THE COMPLAINT

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Published by: Kristal Roberts on Aug 07, 2013
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09/11/2013

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UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIAGILBERTE JILL KELLEY
et al.
,Plaintiffs,v. Civil Action No. 13-cv-825 (ABJ)THE FEDERAL BUREAU OFINVESTIGATION
et al.
,Defendants.DEFENDANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWEROR OTHERWISE RESPOND TO THE COMPLAINT
Defendants respectfully move for an extension of thirty days, until September 4, 2013, toanswer or otherwise respond to the complaint (ECF No. 1). Pursuant to Local Rule 7(m), theundersigned counsel has conferred with counsel for plaintiffs, who represents that he does notoppose this motion. In support of this motion, defendants respectfully submit that there existsgood cause for it to be granted as follows:Defendants seek the additional time requested herein due to the detail and length of thecomplaint (65 pages) and the breadth of the claims brought by plaintiffs, who allege violations of their privacy rights resulting from alleged improper disclosures of confidential, personalinformation. Responding to plaintiffs’ allegations and claims requires that undersigned counselconfer with multiple agencies and several government officials. Although these efforts are beingundertaken diligently and expeditiously, additional time is needed to conclude this process. Thisrequested extension is further motivated by the fact that certain employees of one of thedefendants, the Department of Defense, are currently furloughed one day a week.
Case 1:13-cv-00825-ABJ Document 12 Filed 07/29/13 Page 1 of 2
 
CONCLUSION
 For the foregoing reasons, defendants respectfully request that the Court grant their motion for an extension of time. Attached is a proposed order granting the 30-day extension and setting September 4, 2013, as the due date for answering or otherwise responding to thecomplaint.July 29, 2013 Respectfully Submitted,STUART F. DELERYActing Assistant Attorney GeneralJOHN R. TYLER Assistant Branch Director /s/
Peter J. Phipps
PETER J. PHIPPS (DC Bar #502904)Senior Trial CounselU.S. Department of Justice, Civil DivisionFederal Programs BranchTel: (202) 616-8482Fax: (202) 616-8470Email: peter.phipps@usdoj.govMailing Address:P.O. Box 883 Ben Franklin StationWashington, DC 20044Courier Address:20 Massachusetts Ave., NW, Room 7136Washington, DC 20001
 Attorneys for Defendants
Case 1:13-cv-00825-ABJ Document 12 Filed 07/29/13 Page 2 of 2

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