Third 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.             |

PLAINTIFF'S THIRD MOTION TO EXTEND TIME TO OPPOSE THE FEDERAL AND DISTRICT OF COLUMBIA DEFENDANTS' RESPECTIVE MOTIONS TO DISMISS OR IN THE ALTERNATIVE FOR SUMMARY JUDGMENT, AND REPLY TO DEFENDANTS' OPPOSITION TO PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION

In an Order, filed July 7, 1995, the Court acknowledged receipt of two Motions for Enlargement of Time, and correctly construed plaintiff's Motions as requests to extend the time for filing an Opposition to the Federal Defendants' Motion to Dismiss or, in the Alternative, for Summary Judgment and the Corporation Counsel's Motion to Dismiss or, in the Alternative, for Summary Judgment. Not only did the Court grant the amount of time requested by plaintiff, indeed the Court allowed more time than plaintiff requested, allowing until 4:00 p.m. on July 12, 1995 in which plaintiff might file an Opposition to the Defendants' dispositive Motions.

In a11 sincerity, plaintiff extends appreciation for the patience demonstrated the Court's generous extentions. Plaintiff wants to believe the Court's forbearance indicates discernment of the unique difficulties under which plaintiff labors.

With good reason, the Court also noted the "anticipat(ion) that the Plaintiff will be seeking no further extensions of time for filing."

Plaintiff assures the Court that he fully comprehends the need for swift action in judicial matters, and it would be mistaken to construe plaintiff's repeated inability to meet filing deadlines in this case as an indication of disrespect or attempt at delay.

Rather, in the interests of justice, plaintiff's tardiness should be considered as nothing more than a reflection of his personal physical, intellectual and material limitations.

Upon the foregoing, the additional representation set forth in the accompanyinq Memorandum of Points and Authorities in further support of this motion, with great chargrin and feelings of inadequacy, plaintiff finds no alternative but to request yet another extension of time in which to file an opposition to defendants' aforesaid dispositve motions.

Plaintiff has not been able to contact defense counsel, but can't imagine how they might be harmed by the addition delay,

A proposed Order is attached.

Respectfully submitted this 12th day of July, 1995.

_______________________________________
William Thomas, Plaintiff Pro Se
2817 11th Street N.W.,
Washington, D.C. 20005
202-462-0757

CERTIFICATE OF SERVICE

I certify that, on this 12th day of July, 1995, copies of PLAINTIFF'S THIRD MOTION TO EXTEND TIME TO OPPOSE THE FEDERAL AND DISTRICT OF COLUMBIA DEFENDANTS' RESPECTIVE MOTIONS TO DISMISS OR IN THE ALTERNATIVE FOR SUMMARY JUDGMENT, AND REPLY TO DEFENDANTS' OPPOSITION TO PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION, were served by first-class mail, addressed to:
MARINA UTGOFF BRASWELL,
Assistant United States Attorney,
Judiciary Center Building -- Rm. 10-820,
555 4th Street, N.W.,
Washington, D.C. 20001,
and

BRUCE BRENNAN,
Asst. Corporation Counsel,
441 4th Street NW ,
Suite 6-S-101,
Washington, D.C. 20001.