UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
WILLIAM THOMAS,                  )
       	Plaintiff,	         )
                                 )
	  v.	                 )     Civil Action No. 97-0712  (TFH)
		                 )
                                 )
CHRISTIAN STANTON, et al.,       )
	  Defendants.            )
PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION
OF TIME TO OPPOSE DEFENDANTS' PARTIAL MOTION TO DISMISS

Plaintiff moves the Court for a 30-day extension of time, to and including September 10, 1997, in defendants consents to the granting of this motion and requests that the deadline for filing which to submit plaintiff's opposition to defendants' partial motion to dismiss. Counsel for defendants' reply also be extended. In support of this motion, plaintiff relies on the accompanying memorandum.

Respectfully submitted,

Alisa A. Wilkins, D.C. Bar #440880
Gaffney & Schember, P.C.
1666 Connecticut Avenue, N.W., Ste. 225
Washington, D.C. 20009
202/328-2244

Counsel for Plaintiff

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
WILLIAM THOMAS,                  )
       	Plaintiff,	         )
                                 )
	  v.	                 )     Civil Action No. 97-0712  (TFH)
		                 )
                                 )
CHRISTIAN STANTON, et al.,       )
	  Defendants.            )
MEMORANDUM IN SUPPORT OF
PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME
TO OPPOSE DEFENDANTS' PARTIAL MOTION TO DISMISS

Plaintiff's opposition to defendants' Partial Motion to Dismiss currently is due August 11, 1997. Due to the numerous issues of law and fact raised by defendants' lengthy motion and plaintiffs counsel's unusually heavy schedule of pleadings and court appearances at the present time, plaintiff needs an extension of time in order to prepare and file a proper response.

By telephone conference on August 7, 1997, counsel for plaintiff obtained the consent of Stacy Ludwig, counsel for defendants, to the granting of plaintiff's motion. Ms. Ludwig requested, however, and plaintiff's counsel consented to, the extension of the deadline for any reply to September 30, 1997, due to the timing of plaintiffs opposition and Ms. Ludwig's heavy trial preparation schedule in September.

Plaintiff's motion should be granted.

Respectfully submitted,
. Alisa A. Wilkins, D.C. Bar #440880
Gaffney & Schember, P.C.
1666 Connecticut Avenue, N.W.,., Ste. 225
Washington, D.C... 20009
202/328-2244

Counsel for Plaintiff

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
WILLIAM THOMAS,                  )
       	Plaintiff,	         )
                                 )
	  v.	                 )     Civil Action No. 97-0712  (TFH)
		                 )
                                 )
CHRISTIAN STANTON, et al.,       )
	  Defendants.            )
ORDER

This matter having come before the Court on plaintiff' motion for a 30-day extension of time to oppose defendants' partial motion to dismiss, it is this day of , 1997,

ORDERED, that plaintiff's motion is granted. Plaintiff shall have until September 10, 1997 to oppose defendants' partial motion to dismiss; and it is

FURTHER ORDERED, that defendants shall have until September 30, 1997 to file any reply to plaintiffs opposition.

United States District Judge

Copies to:

Stacy M. Ludwig
Assistant United States Attorney
Judiciary Center Building
555 4th Street, N.W., Room 10-806
Washington, D.C.. 20001
Alisa A. Wilkins
Gaffney & Schember, P.C..
1666 Connecticut Ave., N.W.
Suite 225
Washington, D.C.. 20009

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the foregoing Motion for Extension of Time to Oppose Defendants' Partial Motion to Dismiss, with accompanying memorandum and proposed order, was served, via first class mail, postage prepaid, this 11th day of August, 1997 to:
Stacy M. Ludwig
Assistant United States Attorney
Judiciary Center Building
555 Fourth Street, N.W., Room 10-806
Washington, DC 20001

Alisa A. Wilkins