UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
NATIONAL SECURITY ARCHIVE,
Civil Action No. 1:06cv01080
INTELLIGENCE AGENCY, et al.
CONSENT MOTION FOR ENLARGEMENT OF TIME
Defendants respectfully move this Court, with consent of plaintiff, to be permitted to
answer or otherwise plead in response to plaintiff’s Complaint (Docket Entry No. 1) on or before
August 16, 2006. Good cause exists for this Motion.
Plaintiff filed its Complaint in this Court on June 14, 2006, and attempted to serve it upon
defendants pursuant to Federal Rule of Civil Procedure 4(i) including by, inter alia, attempting to
serve it upon the U.S. Attorney for the District of Columbia. Although plaintiff sent its
Complaint via certified U.S. Postal Service mail to the U.S. Attorney, it was never received by
his office but, instead, was apparently received by another Department of Justice mailroom.
Undersigned counsel did not receive a copy of plaintiff’s Complaint until the afternoon of Friday,
July 14. Based upon the return of service filed by plaintiff, however, (which includes a certified
mail return receipt bearing the signature-stamp of an employee of the Main Department of Justice
mailroom, not an employee of the U.S. Attorney’s office), defendants’ Answer is due on
Monday, July 17.
Case 1:06-cv-01080-GK Document 9 Filed 07/17/2006 Page 1 of 3
NATIONAL SECURITY ARCHIVE v. CENTRAL INTELLIGENCE AGENCY et al
Plaintiff’s Complaint raises challenges under the Administrative Procedure Act and the
Freedom of Information Act (“FOIA”) to defendants’ application of a Central Intelligence
Agency (“CIA”) regulation, 32 C.F. R. § 1900.02(h)(3), to requests by plaintiff for favorable
treatment of certain FOIA requests they have made of the CIA. The time requested is necessary
for defendants to fully investigate, research, consider and respond to plaintiff’s factu