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Case 1:06-cv-00734-RBW Document 25 Filed 12/17/2007 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA




v.



Plaintiff,





JOSE MANUEL VEGA FRANQUI, et al.,
















SYRIAN ARAB REPUBLIC, et al.,












Defendants.



















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Case No. 1:06-CV-00734-RBW

CONSENT MOTION FOR LEAVE TO FILE PLAINTIFFS’

MOTION IN OPPOSITION TO DEFENDANTS’ MOTION TO

DISMISS AND ACCOMPANYING MEMORANDUM OF POINTS

AND AUTHORITIES IN EXCESS OF PAGE LIMITATIONS





COME NOW, the Plaintiffs, by and through counsel, Joshua M. Ambush, of the Law

Offices of Joshua M. Ambush, LLC, and with the consent of counsel for the Great Socialist

People’s Libyan Arab Jamahiriya, hereby move this Court for leave to file Plaintiffs’ Motion in

Opposition to Defendants’ Motion to Dismiss and Accompanying Memorandum of Points and

Authorities, in excess of the 45-page limit set by the Local Rules of this Court.

In support of this request, Plaintiffs hereby state as follows:

1. Additional pages are necessary for the Plaintiffs’ Opposition because the Defendants’

Motion to Dismiss raises complex issues involving sovereign immunity, the application

of various counterterrorism statutes to the Plaintiffs’ claims, equitable tolling issues, and

the statute of limitations; and

2. To properly respond, it is necessary for the Plaintiffs to fully brief the reasons for which

the Court should deny the Defendants’ Motion to Dismiss; and

Case 1:06-cv-00734-RBW Document 25 Filed 12/17/2007 Page 2 of 3

3. Plaintiffs anticipate timely filing their Motion in Opposition to the Defendants’ Motion to

Dismiss on Monday, December 17, 2007.

WHEREFORE, for the reasons set forth above, Plaintiffs’ respectfully request

that this Court grant Plaintiffs’ Consent Motion for Leave to File Plaintiff’s Motion in

Opposition to Defendants Motion to Dismiss and Accompanying Memorandum of Points and

Authorities in Excess of the Page Limitations set by the Local Rules of this Court.

Respectfully submitted,

/s/ Joshua M. Ambush
____________________________________
Joshua M. Ambush (Md. Bar # 27025)
Law Offices of Joshua M. Ambush, LLC
Hilton Plaza
1726 Reisterstown Road
Suite 206
Baltimore, Maryland 21208
410-484-2070
410-484-9330 (facsimile)
[email protected]




CERTIFICATE OF SERVICE


I hereby certify that a true and accurate copy of the foregoing Consent Motion for Leave to File
Plaintiffs’ Motion in Opposition to Defendants’ Motion to Dismiss and Accompanying
Memorandum of Points and Authorities in Excess of Page Limitations was delivered via
electronic filing and/or first class mail postage prepaid, to Thomas J. Whalen, Esquire, Mark A.
Johnston, Esquire, Eckert Seamans Cherin & Mellott, LLC, 1747 Pennsylvania Avenue, N.W.,
Twelfth Floor, Washington, D.C. 20006; Wendy West Feinstein, Eckert Seamans Cherin &
Mellott, LLC, U.S. Steel Tower, 44th Floor, 600 Grant Street, Pittsburgh, PA 15219, this 17th
day of December, 2007.


/s/ Joshua M. Ambush
_____________________________

Case 1:06-cv-00734-RBW Document 25 Filed 12/17/2007 Page 3 of 3

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA




v.



Plaintiff,





JOSE MANUEL VEGA FRANQUI, et al.,
















SYRIAN ARAB REPUBLIC, et al.,












Defendants.



















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Case No. 1:06-CV-00734-RBW

ORDER GRANTING CONSENT MOTION FOR LEAVE TO FILE

PLAINTIFFS’ MOTION IN OPPOSITION TO DEFENDANTS’

MOTION TO DISMISS AND ACCOMPANYING MEMORANDUM

OF POINTS AND AUTHORITIES IN EXCESS OF PAGE LIMITATIONS





This matter having come before the Court on the Plaintiffs’ Consent Motion for

Leave to File Plaintiffs’ Motion in Opposition to the Defendants’ Motion to

Dismiss and Accompanying Memorandum of Points and Authorities in Excess of Page

Limitations, and the Court having been sufficiently advised, it is hereby

ORDERED that Plaintiffs’ Motion is hereby GRANTED and Plaintiffs shall be permitted

to file their Motion in Opposition to Defendants’ Motion to Dismiss and Accompanying

Memorandum of Points and Authorities in excess of the Courts’ Rules on page number

limitations.

IT IS SO ORDERED on this the _______ day of ____________, 2007.






Copies to:
Counsel of Records

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