Motion for extension of time

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UNITED STATES COURT OF APPEALS
DISTRICT OF COLUMBIA CIRCUIT

No.95-5340

September Term, 1996
District Court No. 94cv02747

William Thomas,
Concepcion Picciotto, and
Ellen Thomas.
Appellants

v.

United States of America, et al.,
Appellees

APPELLANTS' MOTION FOR AN EXTENSION OF TIME

Late this afternoon, Kimberly Tarver, counsel for appellees, contacted the undersigned, and informed him that she would require an additional week in which to comply with this Court's September 18, 1996 Order. Ms. Tarver asked whether the undersigned would object to an extension of time in which appellee might file a Motion to Govern Further Proceedings, pursuant to the Court's Order of September 18, 1996.

Appellees have previously portrayed the proceedings below as "complicated" (Appellees' Motion for Summary Affirmance, pg. 4), and appellants must agree.

On one hand appellants, as a result of the lower court's opinion, are suffering a substantial diminishment of their First Amendment exercise, and are very anxious to resolve this matter.

Although eager to bring this matter to a resolution as quickly as possible, appellants appreciate the complicated nature of this case, and the importance of accurately conveying to this Court the issues involved.

Therefore, in the interest of carefully deliberated justice, the undersigned agreed not to oppose an extension of time by appellees in which to file a Motion to Govern Further Proceedings.

Although the undersigned was preparing to file pleadings consistent with the Court's September 18th order before midnight tonight, appellants were not satisfied that the complicated cross-referencing was entirely without error.

Therefore, as appellees have requested an extension of one week from today in which to comply with the Court's Order of September 18th, and since appellants can use additional time to perfect their own Motion to Govern Further Proceedings, in the interests of a well-reasoned, accurate record, appellants also move for an extension of time until October 23, 1996 in which to file their Motion to Govern Further Proceeding pursuant to the decision in Crawford-El v. Britton, US App D C94-7203 (decided August 27, 1996).

Respectfully submitted this 16th day of October, 1996

__________________________________
William Thomas, Appellant, Pro Se
P.O. Box 27217
Washington, D.C. 20038
(202) 462-0757

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the foregoing Motion for Extension of Time in Which to File a Motion to Govern Further Proceedings has been mailed, postage prepaid, this 16th day of October, 1996, to:

Kimberly N. Tarver, Assistant United States Attorney
Judiciary Center Building, 555 4th Street N.W., Rm 10-106
Washington, D.C. 20001

William Thomas Appellant, pro se
P.O. Box 27217
Washington, D.C. 20038
202-462-0757

Motion to Govern Further Proceedings - Next Filing

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