Case 1:08-cv-01046-JDB Document 13 Filed 10/15/2008 Page 1 of 3

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

)
CITIZENS FOR RESPONSIBILITY )
AND ETHICS IN WASHINGTON, )
)
Plaintiff, ) Civil Action No. 08-1046 (JDB)
)
v. )
)
U.S. DEPARTMENT OF )
HOMELAND SECURITY, )
)
Defendant. )
)

DEFENDANT’S CONSENT MOTION FOR AN EXTENSION OF TIME

TO FILE STATUS REPORT

Defendant, by and through undersigned counsel, respectfully moves the Court for an

enlargement of time of two weeks to, and including, October 30, 2008, to submit the status report

to the Court required by the Court’s Order dated September 25, 2008 (Document 10). Specifically,

the Court ordered “the parties to confer to discuss the search for and processing of emails responsive

to the second part of Plaintiff’s FOIA request and submit a status report to the Court by not later than

October 15, 2008.” Defendant, through undersigned counsel, has discussed this request with

plaintiff’s counsel and plaintiff consents to the enlargement.

There is good cause for the requested enlargement of time. The parties conducted a

telephonic conference call on Friday, October 10, 2008, to discuss search terms that may assist in

narrowing the scope of the second part of Plaintiff’s FOIA request. The parties require additional

time to continue to confer and consult about this matter before filing a status report with the Court.

The extension is also required because undersigned counsel, who is entering an appearance in this

case today, will need to complete the discussions initiated Cindy Owens, a Special Assistant United
 Case 1:08-cv-01046-JDB Document 13 Filed 10/15/2008 Page 2 of 3

States Attorney, who was lead counsel on this case and is now on maternity leave. A proposed order

consistent with the relief requested herein is attached.

WHEREFORE, Defendant respectfully requests an enlargement of time of two weeks to file

a status report.

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/
JOHN G. INTERRANTE
PA Bar # 61373
Assistant United States Attorney
Civil Division
555 4th Street, N.W.
Washington, D.C. 20530
(202) 514-7220
(202) 514-8780 (fax)
John.Interrante@usdoj.gov

Of Counsel:

Simon Fisherow, U.S. Customs and Border Protection

David Palmer, U.S. Department of Homeland Security
Susan Shama, U.S. Customs and Border Protection

2
 Case 1:08-cv-01046-JDB Document 13 Filed 10/15/2008 Page 3 of 3

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

)
CITIZENS FOR RESPONSIBILITY )
AND ETHICS IN WASHINGTON, )
)
Plaintiff, ) Civil Action No. 08-1046 (JDB)
)
v. )
)
U.S. DEPARTMENT OF )
HOMELAND SECURITY, )
)
Defendant. )
)

ORDER

Upon Consideration of Defendant’s Consent Motion for Enlargement of Time to File Status

Report, it is hereby ORDERED that the motion is GRANTED.

It is further ORDERED that parties shall submit a status report to the Court by not later than

October 30, 2008.

It is SO ORDERED this day of October, 2008.

John D. Bates
United States District Judge