DC Motion to Dismiss

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.             |

Defendant District of Columbia's Motion to
Dismiss or in the Alternative
for Summary Judgment

Pursuant to Fed. R. Civ. P. Rules 12(b) (6) and 56, Defendants District of Columbia, the Metropolitan Police Department , and Captain Radzilowski ("District Defendants") respectfully request the Court to dismiss Counts 12, 13, and 14 of the complaint or in the alternative grant them summary judgment, as there is no evidence that any constitutional violations occurred and in further support thereof respectfully refer the Court to the attached Memorandum of Points and Authorities.

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, C280461]
Assistant Corporation Counsel, D.C.
Attorney for District Defendants
441 4th Street, N.W.,
Suite 6-S-101
Washington, D.C. 20001