Untitled Document

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MARY HUDDLE, et al.,
              Plaintiffs,

        v.                         Civil Action No. 88-3130-JHG

RONALD WILSON REAGAN, et al., 
Defendants.

MOTION FOR ENLARGEMENT OF TIME

Defendants, by and through their undersigned counsel, hereby move pursuant to Fed. R. Civ. P. 6(b) for an enlargement of time, to and including December 7, 1988, within which to file their opposition to plaintiffs' Motion for a Temporary Restraining Order and Motion for Preliminary Injunction. This short enlargement is necessary due to the press of other matters assigned to Assistant United States Attorney Michael L. Martinez including the fact that he has been out of town the past three days on business related to other assigned matters in the united States Attorney's office. As a result, defendants have been unable thus far to complete their response.

This short enlargement will not harm plaintiffs in this matter. Indeed, it must be noted that plaintiff William Thomas has on two prior occasions sought unsuccessfully to enjoin the application of some of the same regulations he seeks to enjoin in this case. Recently, and in response to Thomas' second attempt at an injunction, Judge Oberdorfer of this Court found the regulation, insofar as it deals with Lafayette Park, 36 C.F.R. 7.96(g)(5)(x)(B)
(1987), to be constitutional. See Thomas v.

United States, Civil Action Nos. 84-3552-LFO, 87-1820-LFO (Sept. 16, 1988). 1/

Wherefore, defendants ask the Court to grant this short enlargement and sign the Order in the form attached. 2/

Respectfully submitted,

//s// jay b. stephens
JAY B. STEPHENS, C BAR #177840
United States Attorney
//s// john d. bates

JOHN D. BATES, D BAR #934927
Assistant United States
Attorney

//s// michael l. marinez
MICHAEL L. MARTINEZ, DC BAR
#347310
Assistant United States Attorney

_______________________________________________

1/ Plaintiffs in that case have filed several Notices of Appeal.

2/ In making this motion defendants do waive any defenses available to them under Fed. R. Civ. P. 12 or otherwise, including immunity from suit.

CERTIFICATE OF SERVICE

I hereby certify that this 2nd day od December, 1988, I sent one copy of the foregoing Motion for Enlargement of Time via first class U.S. mail to the following:

William & Ellen Thomas
1440 N Street, N.W.
#410
Washington, D.C. 20006

Mary Huddle
Sunrise S. Harmony
Scott Galindez
Concepcion Picciotto
Philip Joseph
P.O. Box 27217
Washington, D.C. 20038

//s// Michael L. Martinez

MICHAEL L. MARTINEZ, DC BAR #347310
Assistant United States Attorney
Room 4126 Judiciary Center
555 Fourth Street,
N.W. Washington, D.C. 20001
(202) 272-9195

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MARY HUDDLE, et al.,
              Plaintiffs,

        v.                         Civil Action No. 88-3130-JHG

RONALD WILSON REAGAN, et al., 
Defendants.

ORDER

Upon consideration of defendants' Motion for Enlargement of Time and the entire record in this matter, it is by the Court this day of December, 1988, hereby

ORDERED, that the motion be and hereby is GRANTED, and that the time within which defendants may file their opposition to the Motion for Temporary Restraining Order and Preliminary Injunction be and hereby is enlarged to and including December 7, 1988.

UNITED STATES DISTRICT JUDGE

MICHAEL L. MARTINEZ
Assistant United States
Attorney
Room 4126 Judiciary Center
555 Fourth Street, N.W.
Washington, D.C. 20001

WILLIAM & ELLEN THOMAS
1440 N Street, N.W., #410
Washington, D.C. 20005

MARY HUDDLE
PHILIP JOSEPH
SUNRISE S. HARMONY
CONCEPCION PICCIOTTO
SCOTT GALINDEZ
P.O. Box 27217
Washington, D.C 20038