Opinion
Civil Action No. 07-CV-2338 (UNA)
07-05-2012
ABDURRAHMAN ABDALLAH ALI MAHMOUD AL SHUBATI (ISN 224), Petitioner, v. BARACK H. OBAMA, President of the United States of America, et al., Respondents.
Respectfully submitted, Brent N. Rush forth McKool Smith Counsel for Petitioner Rodney Patton Terry M. Henry Andrew I. Warden Rodney Patton United States Department of Justice Civil Division, Federal Programs Branch Counsel for Respondents
STIPULATION AND ORDER EXTENDING THE STAY BY NINETY DAYS
The parties stipulate that the stay in this case, which is due to expire on June 28, 2012, should be extended for another 90 days. In support of this stipulation, the parties state as follows:
1. On August 9, 2010, the Court granted the parties' joint motion to stay these proceedings until February 6, 2011. (Dkt. No. 228).
2. On February 4, 2011, the Court granted the parties' joint motion to extend the stay of these proceedings until May 31, 2011. (Dkt. No. 235).
3. By Minute Order on July 29, 2011, the Court granted the parties' joint motion to extend the stay of these proceedings until September 30, 2011.
4. On April 24, 2012, the Court granted the parties' stipulation and proposed order extending the stay until June 28, 2012. (Dkt. No. 249).
5. On June 18, 2012, Respondents provided counsel for Petitioner with a copy of the attached memorandum of understanding and are willing, if this case were dismissed without prejudice, to provide Petitioner with continued counsel access to the extent provided, and on the terms set forth, in the memorandum of understanding.
6. The parties have conferred and agree that an extension of the current stay for an additional 90 days is appropriate such that the stay would then expire on September 26, 2012.
7. During this 90-day period, the terms of the Protective Order, including provisions regarding counsel access to Petitioner, will continue to govern this case.
8. During this 90-day period, all discovery obligations and related filing obligations are stayed.
9. Prior to the end of this additional 90 day period, the parties shall confer as to whether further proceedings are necessary or whether the stay should be extended and for how long. If the parties determine that further proceedings are necessary, they shall file with the Court a proposed schedule for such proceedings.
Respectfully submitted,
Brent N. Rush forth
McKool Smith
Counsel for Petitioner
Rodney Patton
Terry M. Henry
Andrew I. Warden
Rodney Patton
United States Department of Justice
Civil Division, Federal Programs Branch
Counsel for Respondents
______________________
Presiding Judge