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 June 26, 1995 the Court entered an Order in this case extending the time in which plaintiff would be permitted to file a response to the Federal and Corporation Defendants dispositive motions until July 5, 1995.

Unexpected delays in another court case and the resolution of baseless and documentation of criminal charges related to this case (Exhibit 1 hereto) have contributed to preventing plaintiff tfrom filing in a timely manner.

Various unexpected delays have combined to preclude plaintiffs from finalizing his crucial pleading due on this date.

Indeed, defendants have advised

"Plaintiff should be aware that under Fed. R. Civ. P. 56 the evidence submitted by federal defendants will be accepted by the Court as true unless plaintiff submits his own affidavits or documentary evidence." Defts' Memo, ftn. [10] Plaintiff has been unable to reproduce a video tape of the actual arrest at issue, and requires extra tiem to accomplish that reproduction. Defendants will not be prejudiced by this short delay, and a fully informed judical opinion would favor it.

Therefore plaintiff requests that the Court grant plaintiff an extension of time up to and including July 10, 1995 in which to respond to the defendants' Motions to Dismiss or Alternatively for Summary Judgement

A Proposed Order is attached.

Respectfully submitted, this 5th day of July, 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.