UNITED STATES DISTRICT COURT
Motion for Enlargement of Time
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. |
MOTION FOR ENLARGEMENT OF TIME
On May 30, 1995 the Court entered an Order in this case
directing the federal defendants and the Corporation Counsel to
file dispositive motions on or before June 14, 1995, and
directing plaintiff to file any replies on or before June 21st.
On June 14, 1995 the federal defendants filed a voluminous
Motion to Dismiss or Alternatively for Summary Judgement.
Also on June 15, 1995 the Court granted a motion by the
Corporation Counsel extending the time for the Corporation
Counsel to file dispositive pleadings until June 21st.
Frankly, plaintiff simply will not be able to finalize a
response to the federal defendants' Motion to Dismiss by the
close of business today.
Moreover, because the federal defendants and the District of
Columbia defendants are co-defendants jointly involved in the
same alleged transactions, plaintiff requests the Court to extend
the time in which he may reply to the federal defendants' Motion
to Dismiss until after he has had an opportunity to review the
District of Columbia's pleadings, thus insuring that "plaintiff
(who) should be aware that ... evidence submitted by federal
defendants will be accepted by the Court as true..." (federal
Defendants' Memo. ftn. 10), will be able to respond fully to the
related claims raised by co-defendants.
By the Order of June 15, 1995 plaintiff has been directed to
respond to the Corporation Counsel's filings, presently due on
June 21, 1995, by June 28, 1995. The Corporation Counsel has
been serving his papers by mail, and the added delay will not
provide plaintiff adequate time to reply by June 28, 1995.
Therefore plaintiff requests that the Court grant plaintiff
an extension of time up to and including July 3, 1995 in which to
respond to the federal defendants' Motion to Dismiss or
Alternatively for Summary Judgement, and to whatever pleading the
Corporation Counsel may file on June 21, 1995.
A Proposed Order is attached.
Respectfully submitted this 21st day of June, 1995,
William Thomas, pro se
2817 11th Street N.W.
Washington, D.C. 20001
CERTIFICATE OF SERVICE
On _________, 1995, I caused a copy of the accompanying
Motion for Enlargement of Time to be served upon the office of
AUSA Marina Utgoff Braswell, Assistant United States Attorney for
the District of Columbia at 555 4th Street NW, Washington, D.C.,
and Bruce Brennan, Assistant Corporation Counsel for the District
of Columbia, Civil Division, 441 4th Street, NW, Washington, D.C.
20001, by first class U.S. mail.