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Case 1:07-cv-01842-HHK Document 7 Filed 04/01/2008 Page 1 of 4

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

Plaintiff,



OSAMA ABDELFATTAH, )
)
)
)
v. )
)
DEPARTMENT OF HOMELAND, )
)
SECURITY, ET AL.,
)
)
)
__________________________________________)


Defendants.





No. 1:07-cv-01842-HHK

DEFENDANT=S CONSENT MOTION FOR AN EXTENSION OF TIME

TO RESPOND TO THE COMPLAINT




Pursuant to Rule 6(b)(1) of the Federal Rules of Civil Procedure, Defendants1, through

undersigned counsel, move this Court to enlarge the time from April 7, 2008, to June 6, 2008, for

Defendant to file a dispositive motion. Pursuant to Rule 7(m) of the Rules of the United States

District Court for the District of Columbia, the undersigned counsel conferred Plaintiff on the

extension motion via telephone on Monday, March 31, 2008, and Plaintiff consented to the relief

requested.



There is good cause for the Court to grant this Motion. The Plaintiff has named four

federal agency defendants in his Complaint, and referred to additional ones such as the Federal

Bureau of Investigation, in the body of his complaint. See e.g., Complaint, ¶ 5. Until recently,

undersigned counsel had difficulty indentifying the agency counsel assigned to this case, and for

only a few days has he been able to investigate the issues presented and begin coordinating a


1 The Defendants being represented by undersigned counsel in this case are the U.S. Department of Homeland
Security, and its agencies U.S. Immigration and Customs Enforcement, U.S. Citizenship and Immigration Services,
and U.S. Customs and Border Protection. Plaintiff also lists as defendants “JOHN DOES” and “JOHN DOES
Companies,” which undersigned counsel does not represent, as they have yet to be identified.

Case 1:07-cv-01842-HHK Document 7 Filed 04/01/2008 Page 2 of 4

response to the Complaint. The undersigned counsel needs an additional sixty to respond

appropriately to the Plaintiff’s complaint. The extension is needed so that the undersigned

counsel can work with agency counsel further and prepare a response for client and supervisory

review prior to filing it with the Court. This is Defendant’s first Motion for an Extension of

Time to Respond to the Complaint.

For these reasons, the Defendant requests that the Court extend the deadline until June 6,

2008, for Defendant to respond to the Complaint.



Dated: April 1, 2008.



















Respectfully Submitted,







/s/ ___________________________________
JEFFREY A. TAYLOR, D.C. BAR # 498610
United States Attorney

/s/ _______________________________
RUDOLPH CONTRERAS, D.C. BAR #434122
Assistant United States Attorney


/s/____________________________________
BRANDON L. LOWY
Special Assistant United States Attorney
555 Fourth Street, N.W.
Washington, D.C. 20530
(202) 307-0364


Attorneys for Defendant

Case 1:07-cv-01842-HHK Document 7 Filed 04/01/2008 Page 3 of 4





CERTIFICATE OF SERVICE

I hereby certify that on this 1st day of April, 2008, I caused the foregoing Defendant’s

Respondents’ Motion for an Extension of Time to Respond to the Complaint to be filed via the

Court’s Electronic Case Filing system, and served upon plaintiff by first-class mail, postage

prepaid, addressed as follows:

OSAMA ABDELFATTAH
3118 Birchwood Ct.
North Brunswick, NJ 08902




___/s/_______________________
BRANDON L. LOWY


Case 1:07-cv-01842-HHK Document 7 Filed 04/01/2008 Page 4 of 4

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

Plaintiff,



OSAMA ABDELFATTAH, )
)
)
)
v. )
)
DEPARTMENT OF HOMELAND, )
)
SECURITY, ET AL.,
)
)
)
__________________________________________)


Defendants.





No. 1:07-cv-01842-HHK

ORDER

Upon consideration of Defendant=s Motion for an Extension of Time to Respond to the

Complaint and the entire record herein, it is this ________ day of _______, 2008,

ORDERED that Defendant=s Consent Motion for an Extension of Time be and is hereby

GRANTED; and it is

FURTHER ORDERED that Defendant shall have up to, and including, June 6, 2008, to

respond to file a dispositive motion.

SO ORDERED.







__________________________
U.S. District Judge