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CITIZENS FOR RESPONSIBILITY )
AND ETHICS IN WASHINGTON, )
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Plaintiff, )
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v. ) Civil Action No. 07-2055 (JDB)
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U.S. DEPARTMENT OF EDUCATION, )
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Defendant. )
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moves the Court for a one-week extension of time, from October 24 to October 31, 2008, to oppose
Plaintiff’s cross-motion for summary judgment. In support of this motion, Defendant states as
follows:
1. By minute order of August 4, 2008, the Court entered the following briefing schedule:
same time, Plaintiff filed a cross-motion for summary judgment. Plaintiff’s cross-motion was not
Case 1:07-cv-02055-JDB Document 16 Filed 10/24/2008 Page 2 of 4
4. Under the current briefing schedule, Defendant’s reply in support of its motion to
dismiss and for summary judgment is due on October 31, 2008. However, pursuant to Local Rule
7(b) and Federal Rule of Civil Procedure 6(d), Defendant’s opposition to Plaintiff’s cross-motion
would reduce litigation costs and conserve judicial resources to combine them into a single
document. Accordingly, to synchronize the briefing schedule, there is good cause to extend by one
6. Pursuant to Local Rule 7(m), undersigned counsel has conferred with Plaintiff’s
WHEREFORE, Defendant respectfully requests that the Court enter an order extending by
one week, from October 24 to October 31, 2008, Defendant’s deadline to oppose Plaintiff’s cross-
GREGORY G. KATSAS
Assistant Attorney General
JEFFREY A. TAYLOR
United States Attorney
JOHN R. TYLER
Senior Trial Counsel
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Case 1:07-cv-02055-JDB Document 16 Filed 10/24/2008 Page 3 of 4
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Case 1:07-cv-02055-JDB Document 16 Filed 10/24/2008 Page 4 of 4
CERTIFICATE OF SERVICE
I hereby certify that on this 24th day of October 2008, I caused the foregoing document to
be served on Plaintiff’s counsel of record electronically by means of the Court’s CM/ECF system.
)
CITIZENS FOR RESPONSIBILITY )
AND ETHICS IN WASHINGTON, )
)
Plaintiff, )
)
v. ) Civil Action No. 07-2055 (JDB)
)
U.S. DEPARTMENT OF EDUCATION, )
)
Defendant. )
)
[PROPOSED] ORDER
For the reasons stated in Defendant’s Consent Motion for Extension of Time, it is hereby
SO ORDERED.
Dated: ___________________________________
JOHN D. BATES
United States District Judge