Case 1:07-cv-01707-HHK-JMF Document 123 Filed 03/02/2009 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

CITIZENS FOR RESPONSIBILITY )

AND ETHICS IN WASHINGTON, )
)
Plaintiff, )
)
v. ) Civil Action No: 1:07-cv-01707 (HHK/JMF)
)
EXECUTIVE OFFICE OF THE )
PRESIDENT, et al., )
)
Defendants. )
)
NATIONAL SECURITY ARCHIVE, )
)
Plaintiff, )
)
v. ) Civil Action No: 1:07-cv-01577 (HHK/JMF)
)
EXECUTIVE OFFICE OF THE )
PRESIDENT, et al., )
)
Defendants. )
)

DEFENDANTS’ UNOPPOSED MOTION FOR ENLARGEMENT

OF TIME TO FILE REPLY IN SUPPORT OF MOTION TO DISMISS

Defendants hereby move the Court for an enlargement of time to file their reply to

plaintiffs’ oppositions to defendants’ motion to dismiss until March 16, 2009. The reply

currently is due to be filed on March 2, 2009. Additional time is required to thoroughly address

the issues raised in the two opposition memoranda filed by plaintiff Citizens for Responsibility

and Ethics in Washington and by plaintiff National Security Archive.

 Case 1:07-cv-01707-HHK-JMF Document 123 Filed 03/02/2009 Page 2 of 3

Pursuant to Local Rule 7(m), counsel for the defendants consulted with counsel for both

plaintiffs, who stated that they do not oppose this motion.

CONCLUSION

For the foregoing reasons, defendants’ motion for an enlargement of time to file their

reply in support of motion to dismiss, until March 16, 2009, should be granted.

Dated: March 2, 2009 Respectfully submitted,

MICHAEL F. HERTZ
Acting Assistant Attorney General

ELIZABETH J. SHAPIRO
Deputy Branch Director

/s/ Carlotta P. Wells

CARLOTTA P. WELLS
TAMRA T. MOORE
Attorneys
U.S. Department of Justice, Civil Division
P.O. Box 883, 20 Massachusetts Ave., NW
Washington, D.C. 20044
Telephone: (202) 514-4522
Fax: (202) 616-8470
carlotta.wells@usdoj.gov

Counsel for Defendants

-2-
 Case 1:07-cv-01707-HHK-JMF Document 123 Filed 03/02/2009 Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on March 2, 2009, a true and correct copy of the foregoing

Unopposed Motion for Enlargement of Time to File Reply in Support of Defendants’ Motion to

Dismiss was served electronically by the U.S. District Court for the District of Columbia

Electronic Document Filing System (ECF) and that the document is available on the ECF system.

/s/ Carlotta P. Wells

CARLOTTA P. WELLS
 Case 1:07-cv-01707-HHK-JMF Document 123-2 Filed 03/02/2009 Page 1 of 1

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

CITIZENS FOR RESPONSIBILITY )

AND ETHICS IN WASHINGTON, )
)
Plaintiff, )
)
v. ) Civil Action No: 1:07-cv-01707 (HHK/JMF)
)
EXECUTIVE OFFICE OF THE )
PRESIDENT, et al., )
)
Defendants. )
)
NATIONAL SECURITY ARCHIVE, )
)
Plaintiff, )
)
v. ) Civil Action No: 1:07-cv-01577 (HHK/JMF)
)
EXECUTIVE OFFICE OF THE )
PRESIDENT, et al., )
)
Defendants. )

[PROPOSED] ORDER GRANTING DEFENDANTS’ UNOPPOSED MOTION FOR AN

ENLARGEMENT OF TIME TO FILE REPLY IN SUPPORT OF MOTION TO DISMISS

Upon consideration of defendants’ unopposed motion for enlargement of time to file

reply in support of motion to dismiss, all the parties and arguments of counsel, it is hereby

ORDERED that Defendants’ Motion for an Enlargement of Time is, GRANTED.

Defendants shall have until March 16, 2009 to file the reply in support of motion to dismiss.

Dated: ________________ _______________________________

HONORABLE HENRY K. KENNEDY
United States District Court Judge