Plaintiffs' Motion for Enlargement of Time

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA


     William Thomas, et. al.       |          C.A. No. 94-2742
           Plaintiffs pro se,      |          Judge Charles R. Richey
                                   |
               v.                  |
                                   |
     The United States, et. al.    |
           Defendants.             |

PLAINTIFFS' MOTION FOR ENLARGEMENT OF TIME

Plaintiffs request an extension of one business day in which to file a response to the Federal defendants filed a Reply to Plaintiffs' Opposition to Defendants' Motion to Dismiss or for Summary Judgment.

Defendants' Reply replies heavily upon a letter, written by Defendant Richard Robbins, which was an exhibit in the case Speigel v. Babbitt, 855 F. Supp. 402.

Plaintiffs have referenced this document in one of their more recent filings [1] A delay in acquiring a copy of Mr. Robbins' letter coupled with unexpected delays resolving baseless criminal charges filed against plaintiff W. Thomas, technical difficulties in the preparation of legal documents due in another civil case [2] (not to mention the pressing demands of maintaining

[1 "Defendants' have not supplied a copy of Mr. Robbins' letter referred to in Speigel, and the file room has not had a copy available for public review, so it has not been possible for plaintiffs to ascertain whether the letter at issue in Speigel is susceptible to the same challenges raised by Plaintiffs' Motion to Strike Mr. Myers' letter." Opposition to Defendants' Motion to Dismiss, ftn. 3. ]

[2 See, Thomas v. Clinton, et al, CA No. 95-1018, Motion for Extension of Time, filed July 5, 1995.]

2

a round-the-clock, year-in-year-out vigil, several other issues), and the unavailability of legal resources over the long holiday weekend have combined to preclude plaintiffs from responding to Defendants' Reply by tonight, which plaintiffs reckon to be the deadline.

Defendants will not be prejudiced by this short delay, and the significance attributed by defendants to Mr. Robbins' Speigal letter (particularly considering defendants failure to supply a copy of the letter for the Court's edification and convenience) suggests that the letter, along with plaintiffs' observations regarding its significance, be made part of this record.

In the interests of tolerance and justice plaintiffs request yet another extension of time in which to file their response.

A Proposed Order is attached.

Respectfully submitted this 5th day of June, 1995,

Respectfully submitted,

_____________________________
William Thomas, pro se
2817 11th Street N.W.
Washington, D.C. 20001
202-462-0757

CERTIFICATE OF SERVICE

On July 5, 1995, I caused a copy of the accompanying Motion for Enlargement of Time to be served by addressing it to f AUSA Kimberly Tarver, Assistant United States Attorney for the District of Columbia at 555 4th Street NW, Washington, D.C., and mailing it first class U.S. postage prepaid mail.

Respectfully submitted this 5th day of June, 1995,

___________________________________
William Thomas, Plaintiff pro se
2817 11th Street N.W.
Washington, D.C. 20001
(202) 462-0757