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Case 1:06-cv-00883-JGP

Document 32

Filed 08/25/2006

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

CITIZENS FOR RESPONSIBILITY RESPO NSIBILITY AND ETHICS IN WASHINGTON, Plaintiff, v. UNITED STATES DEPARTMENT OF HOMELAND SECURITY, Defendant.

DEMOCRATIC NATIONAL COMMITTEE Plaintiff, v. UNITED STATES SECRET SERVICE, Defendant.

Civil Action No. 06-883 (Penn)

Civil Action No. 06-842 (Penn)

UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND TO CITIZENS FOR RESPONSIBILITY AND ETHICS IN WASHINGTON’S SECOND AMENDED COMPLAINT

The United States Department of Homeland Homeland Security (“DHS”), (“DHS”), through undersigned counsel, hereby moves this Court for a five (5) day extension of time, until August 30, to answer or otherwise respond to Citizens for Responsibility and Ethics in Washington’s (“CREW’s”) Second Amended Complaint. The reason for for the request request are as follows: 1.

DHS’ DHS’ss fili filing ng is curr curren entl tly y due due on Augu August st 25, 25, 2006 2006..

2.

Addi Additi tion onal al time time is req reque uest sted ed so so that that DHS’ DHS’ss res respon ponse se can can be coord coordin inat ated ed wit with h the the

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Case 1:06-cv-00883-JGP

Document 32

Filed 08/25/2006

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relevant individuals and finalized for filing. 3.

This This is DHS’ DHS’ss fir first st requ reques estt for for an exte extens nsio ion n of of time time to ans answe werr or or othe otherw rwis isee

respond to CREW’s Second Amended Complaint. 4.

Pursu Pursuant ant to Loc Local al Rul Rulee 7(m) 7(m),, Justi Justin n Sandb Sandber erg, g, coun counse sell for DHS DHS,, conta contact cted ed plai plaint ntif iffs fs’’

counsel. CREW’s counsel, Melanie Melanie Sloan (who stated that she was authorized to speak for for Ms. Weismann and Ms. Eubanks), stated that she does not object to the requested extension of time. Counsel for the Democratic National Committee, Joseph Sandler, similarly stated that he does not object to the requested extension. Accordingly, DHS requests an extension of time of five (5) days to answer or otherwise respond to CREW’s Second Amended Complaint, making the filing due on or before August 30, 2006.

Dated: August 25, 2006

Respectfully submitted, PETER D. KEISLER  Assistant Attorney General KENNETH L. WAINSTEIN United States Attorney CARL J. NICHOLS Deputy Assistant Attorney General JOSEPH H. HUNT Branch Director  

OF COUNSEL: MOLLY WEBER United States Secret Service

s/ Justin M. Sandberg ELIZABETH J. SHAPIRO (D.C. Bar No. 418925) Assistant Branch Director  SARA CLASH-DREXLER  (Pa. Bar No. 86517)

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Case 1:06-cv-00883-JGP

Document 32

Filed 08/25/2006

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Trial Attorney JUSTIN M. SANDBERG (Ill. Bar. No. 6278377) Trial Attorney United States Department of Justice Civil Division, Federal Programs Branch 20 Massachusetts Avenue, N.W. #7224 P.O. Box 883 Ben Franklin Station Washington, D.C. 20044 Telephone: (202) 514-3489 Facsimile: (202) 616-8202 E-mail: [email protected] Attorneys for Defendant

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