Opposition of Ellen Thomas

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.             |

PLAINTIFF ELLEN THOMAS' OPPOSITION TO
PLAINTIFF WILLIAM THOMAS' MOTION TO DISMISS FOR FRIVOLITY

BACKGROUND

Because I am disappointed that the Court didn't grant our Application for a Temporary Restraining Order, although I didn't sign it, I would unreservedly join in his Motion to Reconsider Denial of the TRO Application.

However, I didn't sign Thomas' Motion for Reconsideration because of his Alternative Motion to Dismiss the Complaint for Frivolous, filed January 11, 1995. The reason is because I don't think the case is at all frivolous.

DISCUSSION

I file this motion after considerable reflection, because ordinarily I have confidence in Thomas' ability to speak for me even if he's not a lawyer. But this once I told him his creative pen, however well-intentioned, verged on sarcasm, and I didn't want to be party to the Motion to Dismiss for Frivolity. Thomas insisted on filing it just the same.

He said that he and I simply disagreed, but didn't have time to talk about it because of the filing deadline. He also said, our personal disagreement wouldn't have any adverse impact on our joint claims because I could assert my opposition to his motion under Rule 13(g).

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CONCLUSION

I don't want to risk irritating the Court into a potentially tragic opinion. A lot of people's rights are at stake here. It would be unfortunate to give the police the signal that it's okay to kick and hit people if they're suspected of violating a minor regulation, and, should the person rebel against such contemptuous treatment, then it's okay for the police to kill him. If the police aren't held to civilized standards of behavior, what's worng with death squads?.

Respectfully submitted this 1st day of February, 1995,



______________________
Ellen Thomas
2817 11th St NW #B
Washington DC 20001
202-462-0757

CERTIFICATE OF SERVICE

I hereby state that, on February 1, 1995, I served a copy of the foregoing Plaintiff Ellen Thomas' Opposition to Plaintiff William Thomas' Motion to Dismiss for Frivolity upon the office of Assistant United States Attorney Sally Rider at 555 4th Street NW, Washington, D.C. ROOM 10-808, by placing it in the United States mail, first class postage prepaid.

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