v.                            Civil Action No. 87-3290-LFO

DONALD MODEL, et. al.,

Motion For Enlargement Of Time

On or about February 25, 1988 this Court filed an Order and Memorandum disposing of certain claims and dismissing the Washington Times and Jay Young as defendants in this case.

In the wake of the Court's Order plaintiffs believe it would be a to submit believe it would be appropriate to submit a pleading to direct the Court's attention to facts, alleged in the Complaint, which were either overlooked or construed in the Court's Memorandum.

Plaintiff William Thomas has been soley responsible for plaintiffs' paperwork in this case, and is presently incarcerated under color of a federal "camping" regulation. 1/

1/ See Thomas v. USA Civil #84-3552, Amended Complaint, proposed Order, filed October 19, 1985, definition of the "camping" regulation under which Thomas is imprisoned. This Court has now Ordered that the remaining claims and defendants in this case be consolidated Thomas 84-3552. The Court had previously a denied a motion by plaintiffs to Consolidate these two actions.


On or about March 4, 1988 Thomas was transferred from the Occoquan Correctional facility to the Loudon County Jail. Despite repeated requests there Despite repeated requests there has been no explanation as to why a prisoner sentenced under a federal statute is imprisoned in a County Jail.

During the process of his transfer all of Thoomas' legal materials, incluing the entire record of this case, and address of the defendant were seized by officials at the D.C. Jail. The only explanation given for the seizure of those materials was that it was done at the direction of the U.S. Attorney's Office.

It appears plaintiffs will require aditional time to replace the materials which have been seized.

Therefore plaintiffs move the Court to grant an enlargement of time until May 18, 1988 within which to file an appropriate response to this Court's Memorandum and Order of or about February 25, 1988.

I, William Thomas under penalty of perjury that the foregoing is true and correct to the best of my knowledge and recollection.

Respectfully submitted

(signed W. Thomas)
P.O. Box 340
Loudon County Jail
Leesburg, Virginia