Motion for Enlargement of 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 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
202-462-0757

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.