THOMAS v. REAGAN
USDC Cr. No. 84-3552
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
WILLIAM THOMAS,
Plaintiff,
v. Civil Action No. 84-3552
RONALD REAGAN, et al.,
Defendants.
MEMORANDUM IN SUPPORT OF FEDERAL DEFENDANTS'
MOTION FOR ENLARGMENT OF TIME
Plaintiff filed this action in late November 1984. A re-
sponse is presently due, assuming proper service, on or about
January 29, 1985. Although we have not yet determined the
sufficiency of service on all federal defendants, some of the
individual federal defendants, on whose behalf this motion is
filed, have obtained copies of the summons and complaint in
this action. [2]
All federal defendants respectfully request an enlargement
of time, to and including February 5, 1985. The requested ex-
tension is necessary to allow these individually sued employees
of the United States government to request and obtain representation
from the Justice Department. See 28 C.F.R. §50.15. The processing
of representation requests has not yet been completed for all
defendants, in part because of delays in service of plaintiff's
[2 Defendants do not waive any defense available to them pursuant
to Rule 12(h) or otherwise by filing this motion.]
2
complaint.
Accordingly, defendants request that they be permitted
until February 5, 1985, within which to move, answer or
otherwise respond to plaintiff's complaint.
Respectfully submitted,
JOSEPH E. DIGENOVA
United States Attorney
ROYCE C. LAMBERTH
Assistant United States Attorney
JOHN D. BATES
Assistant United States Attorney
Case Listing --- Proposition One ---- Peace Park