Statement of Issues to be Raised on Appeal

UNITED STATES COURT OF APPEALS
DISTRICT OF COLUMBIA CIRCUIT

No.95-5338

September Term, 1995
USDC No. 95cv01018
William Thomas, et al., Appellants

v.

United States of America, et al., Appellees

STATEMENT OF ISSUES TO BE RAISED ON APPEAL

1. The District Court erred in refusing to Consolidate the instant matter with Thomas v. United States, et al., US Dist Ct No. 94-02747 (currently pending before this Court as USApp. No. 95-5340)

2. The District erred in deciding this case based upon information known to the Court from outside of that proceeding..

3. The District erred in failing to conduct a Preliminary Injunction hearing.

4. The District Court erred in granting defendants' Motion for Summary Judgment by failing to accept the allegations of the Complaint as true, or to construe the Complaint in a light most favorable to Appellant, while refusing to consider evidence submitted by Appellant.

5. The District erred in deciding this case based on unsubstantiated proffers from government counsel..

Respectfully submitted this 30th day of October, 1995,

__________________________
William Thomas, Appellant, pro se
2817 11th Street NW
Washington, D.C. 20038
202-462-0757

CERTIFICATE OF SERVICE
On October 30, 1995, I caused a copy of the Copies of the Statement of Issues to be Raised on Appeal to be served upon the office of the Assistant United States Attorney for the District of Columbia, Appellate Division, at 555 4th Street NW, Washington, D.C., by first class U.S. mail postage prepaid.