Case 1:08-cv-01046-JDB Document 37 Filed 10/02/2009 Page 1 of 2

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 30-DAY STAY

OF SEPTEMBER 1, 2009 ORDER

Defendant, United States Department of Homeland Security (“DHS”), by and through

undersigned counsel, respectfully moves for a 30-day stay of the Court’s September 1, 2009

Memorandum Opinion and Order (Docket Entries 35 and 36) in this case brought under the Freedom

of Information Act (“FOIA”), as amended. Pursuant to Local Rule 7(m), the parties conferred in

this matter, and Plaintiff, through counsel, David Sobel, Esq., consents to this request.

Good cause exists to grant this motion. The stay is requested so that the parties can discuss

a global settlement of all issues relating to the first part of Plaintiff’s FOIA request, including

attorney fees, and eliminate the need for any additional litigation relating to this request. The parties

will submit a report to the Court pertaining to the status of these discussions no later than November

2, 2009. The Court’s September 1, 2009 order will remain in effect except that all deadlines

referenced therein are extended by 30 days. A proposed order is attached.

 Case 1:08-cv-01046-JDB Document 37 Filed 10/02/2009 Page 2 of 2

Respectfully submitted,

/s/
CHANNING D. PHILLIPS, DC BAR #415793
Acting 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, Room E-4806
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

Susan Shama, U.S. Customs and Border Protection
 Case 1:08-cv-01046-JDB Document 37-2 Filed 10/02/2009 Page 1 of 1

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 United States Department of Homeland Security’s

consent Motion for 30-Day Stay of September 1, 2009 Order, for good cause shown, and the

entire record herein, it is hereby ORDERED that the motion is GRANTED.

It is further ORDERED that this Court’s Order dated September 1, 2009 (Docket Entry

36) is stayed until November 2, 2009 and all deadlines contained therein are extended by 30

days.

It is further ORDERED that parties will submit a report to the Court pertaining to the

status of the settlement discussions no later than November 2, 2009.

It is SO ORDERED this day of , 2009.

John D. Bates
United States District Judge