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Case 1:20-cv-03460-KBJ Document 35 Filed 03/19/21 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA

Carter PAGE, )
)
Plaintiff, )
)
v. )
) Case No. 1:20-cv-03460
JAMES COMEY, et al., )
)
Defendants. )
)

OFFICIAL CAPACITY DEFENDANTS’ UNOPPOSED MOTION


FOR A SECOND EXTENSION OF TIME TO RESPOND TO THE COMPLAINT

Defendants the United States, the Department of Justice, and the Federal Bureau of

Investigation (collectively, “Government Defendants”) respectfully move for an extension of

their deadline to respond to the Complaint, up through and including May 18, 2021.

Undersigned counsel has conferred with Plaintiff’s counsel, who consents to the relief requested

herein. Undersigned counsel also conferred with counsel for individual Defendant James

Comey, who consents to the relief requested as well. The other individual defendants have not

yet appeared in this action, and undersigned counsel is not aware of any objection to the

proposed relief.

This is the second extension of the deadline to respond to the Complaint. The Court

previously granted a motion to extend the deadline to March 26, 2021 for the Government

defendants and the individual defendants. See Minute Order dated Feb. 16, 2021 (granting

motion); Minute Order dated Mar. 16, 2021 (granting motion for clarification).

This motion is supported by good cause, including the press of other business and the

need to coordinate multiple components of the Department of Justice to provide input on a

motion to dismiss claims presenting multiple complex legal issues related to national security. It
Case 1:20-cv-03460-KBJ Document 35 Filed 03/19/21 Page 2 of 2

is also the understanding of Government defendants that at least some of the individual

defendants will be represented by private counsel, and that some of the individual defendants or

their counsel are likely to seek extensions as well both to secure representation and to prepare a

response to the Complaint. Government Defendants will consent to any reasonable extension but

are not seeking extensions on their behalf.

Dated: March 19, 2021 Respectfully Submitted,

BRIAN BOYNTON
Acting Assistant Attorney General

MARCIA BERMAN
Assistant Director, Federal Programs Branch

/s/Amy E. Powell
AMY E. POWELL
Trial Attorney, Federal Programs Branch
Civil Division, Department of Justice
c/o U.S. Attorney’s Office
150 Fayetteville St., Suite 2100
Raleigh, NC 27601
Phone: 919-856-4013
Email: amy.powell@usdoj.gov

Attorneys for Defendants Department of


Justice and Federal Bureau of Investigation

/s/ Daniel P. Chung


DANIEL P. CHUNG
CATE E. CARDINALE
Trial Attorneys, Torts Branch
Civil Division
United States Department of Justice
P.O. Box 888 Ben Franklin Station
Washington, DC 20044
Phone: (202) 616-4258
Email: Daniel.P.Chung@usdoj.gov

Attorneys for the United States of America


Case 1:20-cv-03460-KBJ Document 35-1 Filed 03/19/21 Page 1 of 1

IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA

Carter PAGE, )
)
Plaintiff, )
)
v. )
) Case No. 1:20-cv-03460
JAMES COMEY, et al., )
)
Defendants. )
)

[PROPOSED] ORDER

Having considered the Official Capacity Defendants’ Unopposed Motion For an

Extension of Time, the motion is HEREBY GRANTED; and it is hereby ORDERED that the

Government Defendants shall file their response to the Complaint on or before May 18, 2021.

SO ORDERED.

U.S. DISTRICT COURT JUDGE

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