THOMAS v. REAGAN

USDC Cr. No. 84-3552

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
WILLIAM THOMAS                 
           Plaintiff,          
                               
      vs.                                   CA No. 84-3552
                                          Judge Louis Oberdorfer
UNITED STATES OF AMERICA, et. al.          Magistrate Arthur Burnett
          Defendants

PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO AUGUST 25
TO REPLY TO DEFENDANT LINDSEY'S MOTION TO DISMISS
OR FOR SUMMARY JUDGMENT

On August 18, 1986, plaintiff petitioned the Court for an extension of time in which to respond to defendant Lindsey's Motion to Dismiss or for Summary Judgment. Calculating that a minimum of 40 hours would be necessary for the completion of his response, plaintiff fully expected to be filing that document only shortly before 4:00 p.m. on August 21, 1986.

Also on August 18, 1986, plaintiff spoke by phone with the Magistrate's chambers and, upon inquiry, was told that no depositions had as yet been scheduled for defendants Fish, Bangert, or Robbins.

On Tuesday, August 19, 1986, through intermediaries, plaintiff learned that the deposition of Manus J. Fish had been scheduled for 9:30 a.m. August 21, 1986. It had been anticipated that "plaintiff is likely to take some depositions during the week of August 25, 1986" (Federal Defendants' Motion to Alter or Reschedule Date on which Dispositive Motions Are Due, filed August 13, 1986, p. 1), and the August 21, 1986 deposition date came as a surprise.

To prepare for the deposition of defendant Fish, it has been necessary for plaintiff to suspend work on the response to defendant Lindsey's Motion. Plaintiff reckons a minimum of twenty hours of work remain before the completion of his response to defendant Lindsey's Motion. Plaintiff does not expect to be able to return to that task before noon on August 21, 1986.

Therefore, plaintiff asks the Court to extend the time in which he may respond to defendant Lindsey's Motion until August 25, 1986.

Respectfully submitted this _____ day of _________, 1986.

____________________________________
William Thomas, Plaintiff Pro Se
1440 N Street NW, #410
Washington, DC 20005
(202) 462-3542

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