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Case 1:13-cv-00825-ABJ Document 12 Filed 07/29/13 Page 1 of 2

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA GILBERTE JILL KELLEY et al., Plaintiffs, v. THE FEDERAL BUREAU OF INVESTIGATION et al., Defendants. Civil Action No. 13-cv-825 (ABJ)

DEFENDANTS UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND TO THE COMPLAINT Defendants respectfully move for an extension of thirty days, until September 4, 2013, to answer or otherwise respond to the complaint (ECF No. 1). Pursuant to Local Rule 7(m), the undersigned counsel has conferred with counsel for plaintiffs, who represents that he does not oppose this motion. In support of this motion, defendants respectfully submit that there exists good cause for it to be granted as follows: Defendants seek the additional time requested herein due to the detail and length of the complaint (65 pages) and the breadth of the claims brought by plaintiffs, who allege violations of their privacy rights resulting from alleged improper disclosures of confidential, personal information. Responding to plaintiffs allegations and claims requires that undersigned counsel confer with multiple agencies and several government officials. Although these efforts are being undertaken diligently and expeditiously, additional time is needed to conclude this process. This requested extension is further motivated by the fact that certain employees of one of the defendants, the Department of Defense, are currently furloughed one day a week.

Case 1:13-cv-00825-ABJ Document 12 Filed 07/29/13 Page 2 of 2

CONCLUSION For the foregoing reasons, defendants respectfully request that the Court grant their motion for an extension of time. Attached is a proposed order granting the 30-day extension and setting September 4, 2013, as the due date for answering or otherwise responding to the complaint. July 29, 2013 Respectfully Submitted, STUART F. DELERY Acting Assistant Attorney General JOHN R. TYLER Assistant Branch Director

/s/ Peter J. Phipps PETER J. PHIPPS (DC Bar #502904) Senior Trial Counsel U.S. Department of Justice, Civil Division Federal Programs Branch Tel: (202) 616-8482 Fax: (202) 616-8470 Email: peter.phipps@usdoj.gov Mailing Address: P.O. Box 883 Ben Franklin Station Washington, DC 20044 Courier Address: 20 Massachusetts Ave., NW, Room 7136 Washington, DC 20001 Attorneys for Defendants

Case 1:13-cv-00825-ABJ Document 12-1 Filed 07/29/13 Page 1 of 1

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA GILBERTE JILL KELLEY et al., Plaintiffs, v. THE FEDERAL BUREAU OF INVESTIGATION et al., Defendants. Civil Action No. 13-cv-825 (ABJ)

PROPOSED ORDER Defendants Unopposed Motion for Extension of Time to Answer or Otherwise Respond to the Complaint, having come before the Court, and the Court having considered that motion, it is hereby ORDERED that the motion is granted, Defendants shall have until September 4, 2013, to answer or otherwise respond to the Complaint (ECF No. 1).

____________________________________ UNITED STATES DISTRICT JUDGE