Washington, D.C, 20001
and upon counsel for appellee District of Columbia, in the same
manner, addressed to:
Bruce Brennan
Assistant Corporation Counsel, D.C.
Office of the Corporation Counsel
441 4th Street, N.W.
Suite 6-S-101
Washington, D.C. 20001
on this 7th day of December, 1995.
(signed)
MARINA UTGOFF
Assistant United States Attorney
Judiciary Center Building -- Rm. 10-820
555 4th Street, N.W.
Washington, D.C. 20001
(202) 514-7226
3
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
MOTION FOR ENLARGEMENT OF TIME
Federal appellees respectfully move the Court for an
extension of time, to and including December 14, 1995, within
which to file appellees' reply brief to appellant's opposition to
appellees' motion for summary affirmance. Appellees' reply was
due to be filed on December 7, 1995. Appellees' counsel attempted
to reach appellant pro se by telephone today to determine his
position on this motion, but she was not successful.
Counsel for federal appellees has been unable to prepare and
file appellees' reply brief by the date due because of litigation
obligations she has in other cases with deadlines preceding the
one in the instant case. Specifically, since receiving
appellant's reply brief on December 1, 1995, counsel has had
numerous filings due in District court and two appearances in
that Court, one of which was an oral argument on a motion for a
preliminary injunction. Counsel was also out of the office on
sick leave December 4, 1995, and has been assisting in meeting
litigation demands for a colleague who is out on extended sick
leave. The foregoing has impeded the ability of counsel for
appellees to prepare a reply brief in the instant case.
4
Appellees' counsel needs the additional time to permit her
to prepare appellees' reply brief, as well as to provide for
supervisory review and final typing.
WHEREFORE, federal appellees respectfully request that this
Motion For Enlargement Of Time be granted.
(signed)
ERIC H. HOLDER, JR
United States Attorney
(signed)
R. CRAIG LAWRENCE
Assistant United States Attorney
(signed)
MARINA UTGOFF BRASWELL
Assistant United States Attorney
5
CERTIFICATE OF SERVICE
I certify that the accompanying Motion For Enlargement Of
Time was served upon appellant by depositing a copy of it in the
U.S. mail, first class postage prepaid, addressed to:
Mr. William Thomas
2817 llth Street, N.W.
Washington, D.C. 20001
and upon counsel for appellee District of Columbia, in the same
manner, addressed to:
Bruce Brennan
Assistant Corporation Counsel, D.C.
Office of the Corporation Counsel
441 4th Street, N.W.
Suite 6-S-101
Washington, D.C. 20001
on this 7th day of December, 1995.
(signed)
MARINA UTGOFF
Assistant United States Attorney
Judiciary Center Building -- Rm. 10-820
555 4th Street, N.W.
Washington, D.C. 20001
(202) 514-7226