📄 Extracted Text (410 words)
Fr • < >
Subjec :Deliberative
t Process ec aratton rom am Justice - equest or wo ee xtension
Date: Fri, 20 Sep 2013 17:59:47 +0000
Importance: Normal
We have no objection, provided we get the following accommodation, which you already anticipated.
We would request that your motion for extension of time give us an extension on our reply document, such that our reply
would be due 10 days after the main Justice Department declaration that will be coming in two weeks. If you would
include such language as well in any proposed order, saving us (and the court) drafting time, that would be very much
appreciated.
Paul Cassell and Brad Edwards for Jane Doe #1 and Jane Doe #2
Paul G Cassell
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sent: na Se temper 2U ZU13 11:54
u :Deliberative
I rocessDeclaration rom ain Justice - equest for Two Week Extension
Paul and Brad,
I was expecting to file a declaration from the Department of Justice last Friday, September 13, 2013, in support of the
government's assertion of the deliberative process privilege. When I did not receive the declaration, I assumed a decision
had been made not to assert the deliberative process privilege. I went ahead and sought an enlargement of time to file
the United States Attorney's declaration on deliberative process privilege for documents generated by the U.S. Attorney's
Office, which you graciously did not oppose.
I was incorrect in my assumption regarding the Department of Justice making a decision not to assert the deliberative
process privilege. They do want to assert the privilege, and are determining the appropriate DOJ official to execute the
declaration formally invoking the privilege. I will be seeking a two-week extension of time to file the DOJ's declaration,
and I want to know your position on the motion. The government has no objection to petitioners receiving additional
time to respond to the Dal declaration, after it is filed.
I will be filing the United States Attorney's declaration today. Thanks for your consideration.
EFTA00208560
EFTA00208561
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a245d1d394e4f9170c2564f03cac41c3e1ca4200334cffbb7f73097379f1abff
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EFTA00208560
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