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. |
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF
PLAINTIFF'S THIRD MOTION TO EXTEND TIME TO OPPOSE THE FEDERAL AND
DISTRICT OF COLUMBIA DEFENDANTS' RESPECTIVE MOTIONS TO DISMISS OR
IN THE ALTERNATIVE FOR SUMMARY JUDGMENT, AND REPLY TO DEFENDANTS'
OPPOSITION TO PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION
The inherent powers of the court.
Fed. R. Civ. P. Rule 6.
I hereby declare, under penalty of perjury, that the
following is true in every detail.
1. Upon filing my most recent request additional time to
reply to defendants' outstanding pleadings, I was nearly certain
that July 10th would be more than enough time in which to
complete and my outstanding opposition.
2. The video tape exhibit, used as justification for my
most recently requested extension, was actually completed by July
3. After reviewing the tape, certain apparent facts, which
had escaped my attention came to light.
4. During the process of cross-referencing the video tape
to my Opposition, Statement of Facts, and Memorandum, it became
obvious that I could not file the papers which I had prepared,
because the facts that had previously escaped my attention, were
crucial to a meaningful presentation of my case.
5. To make a meaningful presentation of this case has
required a complete restructuring of the documents which had
already been prepared.
6. Even though I am witnessing the thousands of individual
actions which are combining in the preparation of these
documents, it is still difficult for me to understand why this
process has become so time consuming.
7. Perhaps the explanation for my lack of perspective is
due to the fact that I am so consumed by the project.
8. Prior to July 7, 1995, when I filed the most recent
pleadings in Thomas v. United States, et al, USDC CA No 2747, my
time had been divided between those two cases, and several other
9. Since July 7th virtually all my time has been devoted to
the preparation of my instant opposition.
10. During the past 125 hours I have slept 20, with the
exception of time taken for essential bodily functions (not very
much devoted to eating), my every waking hour has been devoted to
finalizing these papers.
11. As it occurred to me that, given my nature, if someone
made the forgoing representations to me I would have to be
skeptical. Anyway, given my nature, I like to test my
perceptions of reality against that of others, so I asked the
people who have been around me almost constantly, what they had
seen me doing since July 7th.
12. They confirmed my impression, saying all they had seen
me doing was to work on these papers. Their expressions, in
response to my questions were quite compelling, and they will,
God willing, be available to testify in corroberation of this
instant declaration should the Court desire further assurance.
13. At this point it seems almost certain that I will be
able to file my opposition by 4:00 p.m. tomorrow, but that would
be rushing, and I would like time to be able to carefully check
the extensive cross referencing, hoping to add as little
additional confusion to this case as possible.
14. Had the Court observed my every activity since the
filing of my last request for an extension of time, I feel
certain, the Court would agree that I had done the very best I
could to beat the clock, but just wasn't fast enough, and
deserved, by the grace of the patient, understanding nature of
justice, additional time to finalize these papers, because I
waasn't wasting time.
15. Therefore, with the most ferverent wish to submit the
most meaningful error-free document possible in the least amount
of time, while obviating the need for further extensions of time,
I would request until July 14, 1995 to file my oppositions.
Respectfully submitted this 12th day of July, 1995.
William Thomas, Plaintiff Pro Se
2817 11th Street N.W.,
Washington, D.C. 20005