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


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