Response to Motion for Enlargement of Time

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

APPELLANT'S RESPONSE TO FEDERAL APPELLEES MOTION FOR ENLARGEMENT OF TIME

For appellees to prevail on their Motion for Summary Affirmance they must show "the merits of this appeal are so clear as to make summary affirmance proper." (Taxpayers Watchdog. Inc. v. Stanley, 810 F.2d 294, 297 (D.C. Cir. 1987).

For the record, in a telephone conversation with appellees' counsel (which apparently took place after appellees' Motion for Enlargement of Time had been filed). appellant admitted that an enlargement of a two or three days would have seemed reasonable. However, in light of appellees' assertion that the merits are so clear, appellant admitted, it was difficult to understand why a week-long extension was necessary to explicate something which must necessarily already be "so clear."

Although counsel's explanation did not seem entirely reasonable, owing to his personal belief that a full and fair hearing should not be thwarted by technicalities, appellant does not object to the requested extension.

Respectfully submitted,

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

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy fothe foregoing Appellant's Response to Federal Appellees' Motion for ENlargement of Time has been mailed, postage prepaid, this 13th day of December 1995, to

Marina Utgoff Braswell
Assistant United States Attorney
Judiciary Center Building
555 4th Street N.W., Rm 10-820
Washington, D.C. 20001

and upon counsel for the 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

William Thomas