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Carter PAGE, )
)
Plaintiff, )
)
v. )
) Case No. 1:20-cv-03460
JAMES COMEY, et al., )
)
Defendants. )
)
Defendants the United States, the Department of Justice, and the Federal Bureau 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
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
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
Carter PAGE, )
)
Plaintiff, )
)
v. )
) Case No. 1:20-cv-03460
JAMES COMEY, et al., )
)
Defendants. )
)
[PROPOSED] ORDER
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.