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Case 1:06-cv-00734-RBW Document 23 Filed 10/17/2007 Page 1 of 4

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA













v.






Plaintiffs







Reverend JOSE MANUEL VEGA FRANQUI
Individually and as Administrator of the
Estate of VASTHI ZILA MORALES DE VEGA,

Et al.










GREAT SOCIALIST PEOPLE’S LIBYAN

ARAB JAMAHIRIYA, et al.









Defendants

























Case No. 06-cv-00734-RBW


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PLAINTIFF’S CONSENT MOTION FOR EXTENSION OF TIME

Plaintiffs, Reverend Jose Manuel Vega Franqui, et al., by undersigned counsel

and with consent of counsel for the Defendant, Great Socialist People’s Libyan Arab

Jamahiriya, et al., hereby moves pursuant to Fed. R Civ. P. Rule 6 for an extension of

approximately sixty (60) days for Plaintiff to respond to the Defendant’s Motion to

Dismiss, on or before December 17, 2007. In support of this Motion, Plaintiff states as

follows:

1. Following a consent extension of time, Defendant has filed, on October 15, 2007,

a Motion to Dismiss pursuant to Fed. R Civ P. 12(b)(1) and 12(b)(6). Plaintiff and

their counsel need time to prepare a response to the issues raised in such Motion.

2. This brief extension will not affect any deadline imposed by the Court, as no

deadlines have yet been set in this case. No party will be prejudiced by this brief

extension.

Case 1:06-cv-00734-RBW Document 23 Filed 10/17/2007 Page 2 of 4

3. No prior request for an extension of time has been made, except for the extension

of time for the Defendant to file their Motion to Dismiss.

4. Undersigned counsel certifies that in accordance with Local Rule LCvR 7(m), he

has consulted with counsel for the Defendant regarding this request for an

extension and Defendants consent to the relief requested herein.

WHEREFORE, Plaintiff requests that the Court grant its Consent Motion for an

approximately sixty (60) day extension to answer, move or otherwise respond to the

Motion to Dismiss on or before December 17, 2007.









LAW OFFICES OF JOSHUA M.
AMBUSH, LLC


/s/_Joshua M.

Ambush_______________________

JOSHUA M. AMBUSH, ESQUIRE
1726 Reisterstown Road, Suite 206
Baltimore, MD 21208
DC Bar Number: MD 27025

Counsel Reverend Jose Manuel Vega Franqui, et al.






X:\Clients\Lod Airport Massacre\documents\Extension.doc








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Case 1:06-cv-00734-RBW Document 23 Filed 10/17/2007 Page 3 of 4

CERTIFICATE OF SERVICE



I HEREBY CERTIFY that a copy of the foregoing Consent Motion for

Extension of Time was electronically filed and served, this 17, day of October, 2007, to:













Mark A. Johnston, Esquire

1747 Pennsylvania Avenue, N.W.

Twelfth Floor

Washington, D.C. 20006
















______________________________
JOSHUA M. AMBUSH, ESQUIRE

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Reverend JOSE MANUEL VEGA FRANQUI
Individually and as Administrator of the
Estate of VASTHI ZILA MORALES DE VEGA,

Et al.










GREAT SOCIALIST PEOPLE’S LIBYAN

ARAB JAMAHIRIYA, et al.











Plaintiffs,





Defendants.





v.

































ORDER

Case No. 06-cv-00734-RBW


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Case 1:06-cv-00734-RBW Document 23 Filed 10/17/2007 Page 4 of 4

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA



Upon consideration of Plaintiff’s Consent Motion for Extension of Time, the

record herein, and the Court being duly advised in the premises, it is, by the Court this

_____ day of October, 2007,




ORDERED, that Plaintiff’s Consent Motion is GRANTED and that Plaintiff

have until December 17, 2007 to answer, move or otherwise respond to the Motion to

Dismiss.

























___________________________
Judge Reggie B. Walton
U.S. District Court for the District of Columbia