Motion of DC Defendants to Extend Time

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA


William Thomas, et. al.       |   
      Plaintiffs pro se,      | 
                              |      
       v.                     |          C.A. No. 95-1018
                              |       Judge Charles R. Richey
The United States, et. al.    |      
      Defendants.             |

MOTION OF DISTRICT OF COLUMBIA DEFENDANTS
TO EXTEND TIME TO RESPOND TO COMPLAINT

Defendants, the District of Columbia, the Metropolitan Police Department, and Captain Radzilowski ("D.C. defendants") move to extend the time to respond to the complaint from June 14, 1995 to June 21, 1995. The U. S. Attorney has authorized undersigned counsel to state that she does not object to this extension. While counsel for these D.C. defendants has been unable to contact-the plaintiff, the accompanying order provides the plaintiff with a similar extension of time. As grounds therefore, counsel states that after the briefing schedule was set by this court, the court entered an order in another, unrelated case (Fraternal Order of Police Metro. Police Dept. Labor Comm, et al.v. D.C., Civil Action No. 95-771 (CRR)) setting an oral hearing for June 14, 1995 for which counsel has been required to prepare. This court has also set a June 19, 1995 date for counsel to submit a written reply in that case. Additional time is therefore needed to respond in this matter. The court is respectfully referred to the

1

accompanyinq Memorandum of Points and Authorities in further support of the motion.

Respectfully submitted,
GARLAND PINKSTON
Acting Corporation Counsel, D.C.
MARTIN L. GROSSMAN
Deputy Corporation Counsel, D.C.
Civil Division
WILLIAM J. EARL
Chief, Major case section

BRUCE BRENNAN, [280461]
Assistant Corporation Counsel, D.C.
Attorney for Defendants
441 4th Street, N.W.,
Suite 6-S-101
Washington, D.C. 20001

CERTIFICATE OF SERVICE

I hereby certify that a copy oE the foregoing Motion for Extension of Time was mailed, first class postage pre-paid this 14th day of June 1995 to

WILLIAM THOMAS
2817 llth St., N.W.
Washington, D.C. 20001

R. CRAIG LAWRENCE, ESQ.
Assistant United States Attorney
MARINA UTGOFF BRASWELL, ESQ.
Assistant United States Attorney
455 4th Street, N.W.
Washington, D.C. 20001

BRUCE BRENNAN
Assistant Corporation Counsel, D.C.