UNITED STATES COURT OF APPEALS
FOR THE DISTRICT OF COLUMBIA CIRCUIT
UNITED STATES 0F AMERICA
v. Criminal No. 87-64
MOTION FOR EXTENSION OF TIME WITHIN WHICH TO FILE
TO GOVERNMENT'S MOTION FOR SUMMARY REVERSAL
The Defendant, Ellen Thomas, through counsel, respectfully
requests, pursuant to U.S. Appeals D. C. Rule 6(b), that this
Court extend the time period within which to file his response
to Government's Motion For Summary Reversal until August 7, 1987.
In support of this motion,counsel states:
1. The Government served its Motion for Summary Reversal
by mailing a copy thereof to counsel on July 21,1987.
2. Counsel did not receive the Government's motion until
July 24, 1987.
3. Because counsel has been involved in extensive preparations
for a criminal trial in D.C. Superior Court set for July 30, 1987,
counsel will not be able to respond to the government's motion
within seven days after receipt of Service.
WHEREFORE, Defendant respectfully requests that this Court
grant this Motion for Extension of Time Within Which to File Response
to Government's Motion for Summary Reversal and extend the time
period for such filing until August 7, 1987.
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing Motion
has been personally served upon John D. Bates, United States Assistant
Attorney, 555 Fourth Street, N.W., Washington, DC 20001, on this
30th of July , 1987.
ROBERT M . HURLEY, # 403467
Attorney for Ellen Thomas
GEORGETOWN CRIMINAL JUSTICE CLINIC
25 E Street, N. W. Second Floor
Washington, DC 20001
( 202 ) 662-9575
ROBERT M. HURLEY