Federal Defendants Motion for Extension 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.             |

FEDERAL DEFENDANTS' UNOPPOSED MOTION FOR ENLARGEMENT OF TIME

Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure, federal defendants respectfully move this Court for an enlargement of time, up to and including August 3, 1995, in which to respond to plaintiff's opposition to federal defendants' dispositive motion and plaintiff's motion to consolidate. Defense counsel's last motion for enlargement of time was premised upon receiving plaintiff's filing no later than July 17, 1995. In fact, "counsel for federal defendants did not receive plaintiff's opposition brief until July 20, 1995. [1] Accompanying plaintiff's brief was a motion to consolidate this case with Thomas v. United States, Civil No. 94-2747 (D.D.C.). In light of defense counsel's schedule since receiving plaintiff's brief, which has consisted of several depositions and court appearances, defense counsel has not had an opportunity to adequately confer with agency representatives and prepare federal defendants' reply brief.

[1 Plaintiff apparently filed his brief at 10:20 p.m. on July 19, 1995, but no copy was delivered to defense counsel on that date.]

1

Consequently, this motion for enlargement of time is necessary in order for defense counsel to coordinate federal defendants' response with various agency representatives and to prepare and finish defendants' brief.

By telephone call on July 27, 1995, plaintiff informed defense counsel that this motion will not be opposed.

Accordingly, for the foregoing reasons, federal defendants respectfully request that this motion for enlargement of time be granted,

Respectfully submitted,

__________________________
ERIC H. HOLDER, JR., D.C. BAR #303115
United States Attorney

MARINA UTGOFF BRASWELL, D.C. BAR #416587
Assistant United States Attorney