CONCEPCION PICCIOTTO, et. al.,
          Plaintiffs,

     v.                            Civil Action No. 87-3290-LFO

DONALD MODEL, et. al.,

On January 26, 1988 this Court filed an Order which dismissed the Complaint as moot.

Due to the fact that he is incarcerated in the Occoquan Correctional facility in Lorton, Virginia, plaintiff William Thomas, who has been responsible for plaintiffs' paperwork in this case, was not appraised of this Court's decision until February 16, 1988, and thus has been unable to respond to the Courtts action until this date.

Therefore, plaintiffs hereby ask for leave to file a motion to reconsider out of time.

Respectfully submitted,

__________________
William Thomas 203-012
Occoquan II, Dorm K-II
P. O. BOX 85
Lorton, Virginia
22079

I, William Thomas, hereby certify that, on this 25th day of February, 1988, a copy of the foregoing Plaintiffs' Motion For Leave To File Out Of Time Plaintiffs' Motion For Reconsideration was served, by first class mail, postage pre-paid, upon AUSA Micheal Martinez, Judiciary Square, 555 4th Street, N.W., Washington, D.C., 20001.