Memorandum in Support of Motion

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.             |

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF
MOTION TO EXTEND TIME TO RESPOND TO THE COMPLAINT

  1. The inherent powers of the court.
  2. Fed. R. Civ. P. Rule 6.
  3. After a briefinq schedule was set by this court, the court entered an order in another, unrelated case (Fraternal Order of Police) settinq an oral hearing for June 14, 1995, the same day this brief is due.
  4. This court has also set a June 19, 1995 due date--for counsel for the defendant's reply to the police union's challenge of wage reductions.
  5. A substantial amount of counsel's time has been consumed in preparation for this hearing.
  6. Counsel is also preparing a separate opposition brief for Am. Fed'n of Gov't Employees, AFL-CTO, et al., v. D.C. (CA No. 951934), now due on June 16, 1995.
  7. The U.S. Attorney has consented to this motion.
  8. Although defendant has not be able to contact the plaintiff, the accompanying order provides the plaintiff with a
    1

    similar extension of time.

Respectfully submitted,

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