UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

WILLIAM THOMAS,                )
              Plaintiff,       )
                               )                       
     v.                        )   Civil Action No. 99-0330           
                               )                      (GK)
OFFICER DAVID LOMBARDI         )  
              Defendants,      )      
_______________________________)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME

The defendant, by and through counsel, respectfully moves this Court pursuant to Rule 6(b)(1), Fed. R. Civ. P., to enlarge the time to answer or otherwise respond to the complaint until June 21, 1999. This request is the third request for an enlargement of time. Plaintiff's counsel consents to this request.

The answer is due on June 14, 1999. Due to the press of other business, the defendant will need more time to respond to the complaint. In particular, the undersigned returned from annual leave on June 2, 1999. A number of matters arose while the undersigned was out of the office that required her immediate attention when she returned, including the breakdown of a settlement in a case that the undersigned believed to be finalized. The undersigned has been working on briefs in other matters and as a result she has not had the opportunity to complete a response in this case by the deadline and will need more time to do so.

WHEREFORE, based on the foregoing, the defendant respectfully requests that the time for answering or otherwise responding to the complaint be extended to and including June 21, 1999. 1/

Respectfully submitted,

(signed)
WILMA A. LEWIS, DC Bar # 358637
United States Attorney

(signed)
Mark E. Nagel, DC Bar #416364
Assistant United States Attorney

(signed)
Stacy M. Ludwig, DC Bar # 445719
Assistant United States Attorney

______________________

1/ Defendant hereby reserves all defenses available to him under Fed. R. Civ. P. 12(b), including qualified immunity.

2

 

CERTIFICATE OF SERVICE

I hereby certify that the foregoing copy of the motion for enlargement of time has been mailed via first class mail, this 11th day of June 1999, addressed to:

Daniel M. Schember
Alisa Wilkins
Gaffney & Schember
1666 Connecticut Avenue, N.W.
Suite 225
Washington D.C. 20009

 

(signed)
STACY M. LUDWIG
Assistant United States Attorney
Judiciary Center Building
555 Fourth St., N.W.
Washington,
D.C. 20001
(202) 514-7147