Memorandum

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.             | 

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT 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

AUTHORITIES

The inherent powers of the court.

Fed. R. Civ. P. Rule 6.

POINTS

I hereby declare, under penalty of perjury, that the following is true in every detail.

1. Upon filing my most recent request additional time to reply to defendants' outstanding pleadings, I was nearly certain that July 10th would be more than enough time in which to complete and my outstanding opposition.

2. The video tape exhibit, used as justification for my most recently requested extension, was actually completed by July 9th.

3. After reviewing the tape, certain apparent facts, which had escaped my attention came to light.

4. During the process of cross-referencing the video tape to my Opposition, Statement of Facts, and Memorandum, it became obvious that I could not file the papers which I had prepared, because the facts that had previously escaped my attention, were crucial to a meaningful presentation of my case.

5. To make a meaningful presentation of this case has required a complete restructuring of the documents which had already been prepared.

6. Even though I am witnessing the thousands of individual actions which are combining in the preparation of these documents, it is still difficult for me to understand why this process has become so time consuming.

7. Perhaps the explanation for my lack of perspective is due to the fact that I am so consumed by the project.

8. Prior to July 7, 1995, when I filed the most recent pleadings in Thomas v. United States, et al, USDC CA No 2747, my time had been divided between those two cases, and several other legitimate tasks.

9. Since July 7th virtually all my time has been devoted to the preparation of my instant opposition.

10. During the past 125 hours I have slept 20, with the exception of time taken for essential bodily functions (not very much devoted to eating), my every waking hour has been devoted to finalizing these papers.

11. As it occurred to me that, given my nature, if someone made the forgoing representations to me I would have to be skeptical. Anyway, given my nature, I like to test my perceptions of reality against that of others, so I asked the people who have been around me almost constantly, what they had seen me doing since July 7th.

12. They confirmed my impression, saying all they had seen me doing was to work on these papers. Their expressions, in response to my questions were quite compelling, and they will, God willing, be available to testify in corroberation of this instant declaration should the Court desire further assurance.

13. At this point it seems almost certain that I will be able to file my opposition by 4:00 p.m. tomorrow, but that would be rushing, and I would like time to be able to carefully check the extensive cross referencing, hoping to add as little additional confusion to this case as possible.

14. Had the Court observed my every activity since the filing of my last request for an extension of time, I feel certain, the Court would agree that I had done the very best I could to beat the clock, but just wasn't fast enough, and deserved, by the grace of the patient, understanding nature of justice, additional time to finalize these papers, because I waasn't wasting time.

15. Therefore, with the most ferverent wish to submit the most meaningful error-free document possible in the least amount of time, while obviating the need for further extensions of time, I would request until July 14, 1995 to file my oppositions.

Respecffully submitted,

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