Motion for Leave to File Out of Time

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA


     William Thomas, et. al.       |          C.A. No. 94-2742
           Plaintiffs pro se,      |          Judge Charles R. Richey
                                   |
               v.                  |
                                   |
     The United States, et. al.    |
           Defendants.             |

MOTION FOR LEAVE TO FILE OUT OF TIME
PLAINTIFFS' RESPONSE TO UNITED STATES' MOTION TO DISMISS

On January 11, 1995 the Court Ordered plaintiffs to address Federal Defendants' Motion to Dismiss (filed the same date) by 4:00 p.m. January 23, 1995.

Due to the complexity of the issues involved, on January 23rd plaintiffs were unable to prepare an appropriate response within the deadline, and moved for an extension of time until 4:00 p.m. on January 24, 1995.

Owing to clerical difficulties, plaintiffs were also unable to meet the 4:00 p.m. deadline on the 24th, and now find it necessary to move for leave to address Defendants' Motion to Dismiss out of time.

A proposed Order is attached.

Respectfully submitted this 24th day of January, 1995,
___________________________________
William Thomas, Plaintiff pro se
2817 11th Street N.W.
Washington, D.C. 20001
(202) 462-0757

CERTIFICATE OF SERVICE

I hereby state that, on January 24, 1995, I mailed, via first class U.S. mail, postage prepaid, a copy of the foregoing Motion for Leave to File Out of Time Plaintiffs' Response to United States' Motion to Dismiss upon the office of the United States Attorney for the District of Columbia at 555 4th Street NW, Washington, D.C.