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.