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KHALID SHAIKH MOHAMMAD , WALID MUHAMMAD SALIH MUBARAK BIN ' ATTAS H, RAMZI BrN AL SHIBH , ALI ABDUL-AZIZ ALl , MUSTAFA AHMED ADAM AL HA WSA WI
14 August 20 12
2. Relief Sought: The defen se seeks an extension of time to respond to AE052 until 13
September 20 12.
3. Facts:
a. On 10 August 20 12, the accu sed were served with AE052. AE052 concerns a
matter of consid erable importance to both the prosecution and the defen se. b. The defendants' response is currently due on 24 August 20 12, during the motions hearin g commenc in g on 22 August 20 12. commiss ion w ill hear 26 mot ions at that hearing.
C.
Counse l for the accused w ill of necess ity devote most of the next two week s to
preparat ion for the 22 Au gust hearin g, makin g an adequate response to AE052 difficu lt or impossible und er the current time frame.
b. AE052 is an important mot ion requirin g an adequate response. The mili tary
commiSS ion w ill benefit from the opportu ni ty for fu ll briefing of the issues presented by the
mot ion. 13 September 20 12 is two weeks from 30 August 20 12, the first day after return from the schedu led hearin g. c. The requested extension until 13 September 20 12 w ill cause no prejud ice to the prosecut ion or the military commiss ion, and w ill not affect the hearing schedu led to beg in on 22 August.
d. By joinin g th is request, the defendants do not wa ive the ir claim for relief in
AE020 Motion for Unspecified Delay in Submission of Responses to Go vernment Motions, Replies to Government Responses to Defense Motions, and Other Requests.
5. Request for Oral Argument: None. 6. Request for Witnesses: None. 7. Conference with Opposing Counsel: The defense has conFerred w ith the government.
The govern ment does not object to the requested relief.
Very respectfully,
IIsll
JAMES G. CONNELL, III Learned Counsel
IIsll
STERLING R. THOMAS Lt Col, USAF Defense Counsel
IIsll
DA VlD Z. NEVIN Learned Counsel
IIsll
DEREK A. POTEET Maj, USMC Defense Counsel
IIsll
JASON D. WRIGHT CPT, USA Defense Counsel
IIsll
C HERYL T BORMA NN Learned Counsel
IIsll
WILLIAM T HENNESSY Maj, USMC Defense Counsel
IIsll
MICHAEL A. SCHWARTZ Capt, USAF Defense Counsel
IIsll
JAMES P. HARRINGTON Learned Counsel
IIsll
KEVIN BOGUCKI LCDR, USN Defense Counsel
IIsll
WALTER B. RUIZ CDR, USN Defense Counsel
CERTIFICATE OF SERVICE
I cert ify that on the 14th day of August, 20 12, I electronicall y filed the fore goin g
document with the Clerk of the Court and served the fore going on all counsel of record by email.
14 August 2012
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