Notice of Filing Amended Complaint

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA


William Thomas, et. al.       |   
      Plaintiffs pro se,      | 
                              |      
       v.                     |          C.A. No. 95-1018
                              |       Judge Charles R. Richey
The United States, et. al.    |      
      Defendants.             |

NOTICE OF FILING AMENDED COMPLAINT

Plaintiff hereby notifies the Court that, pursuant to Fed. R. Civ. P. 15(a), on this date he filed an Amended Complaint.

Pursuant to the colloquy at the May 31st hearing in this matter, and particularly the Court's apparent questions concerning plaintiff's claims and the underlying legal authorities, this Amended Complaint attempts to clarify the statutes unpon which plaintiff relies for relief, by citing as specifically as possible the most relevent provisions of law which plaintiff has been able to identify within the short time period available.[1]

If memory serves correctly the Court advised UUSA Craig Lawerence of its desire to resolve this matter expeditiously and

[1 The Court's reference to his previous courtroom experience, plaintiff believes, might indicate an erroneous assumption regarding plaintiff's legal expertise. The mere fact that he may have appeared in Court far more often than the average layperson cannot and should not, plaintiff suggests, be construed as a the equivilant of passing the Bar Examinations. Nor should it bind plaintiff to a higher standard than that which has be well- established by previous Supreme Court decisions relating to pro se pleadings.

Defects in a pro se plaintiff's pleadings should not bar otherwise substantial claims, since pro se pleadings must be liberally construed to avoid injustice. See, Haines v. Kerner, 404 U.S. 519 (1972).]

1

preclude unnecessary technical delays.

Wherefore, plaintiff hereby moves the Court to revise its' Order of May 31, 1995, which directed "the federal Defendants and the Corporation counsel shall each file a dispositive motion or other responsive pleading on or before Ju(ne) 14, 1995," and direct instead that defendants respond to this Amended Complaint.

Respectfully submitted this 5th day of June, 1995,

___________________________________
William Thomas, Plaintiff pro se
1440 N Street, NW, Apt. 410
Washington, D.C. 20005
202-462-0757

CERTIFICATE OF SERVICE

On June 5, 1995, I mailed a copy of the foregoing Notice of filing an Amended Complaint to the office of the United States Attorney for the District of Columbia, Civil Division, at 555 4th Street NW, Washington, D.C., and upon the office of the Corporation Council for the District of Columbia, Civil Division, at 441 4th Street NW Washington, D.C. 20001.