Federal Defendants Motion for Extension of Time

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.             |

FEDERAL DEFENDANTS' UNOPPOSED MOTION FOR ENLARGEMENT OF TIME

Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure, federal defendants respectfully move this Court for an enlargement of time, up to and including August 25, 1995, in which to respond to plaintiff's opposition to federal defendants' dispositive motion and plaintiff's motion to consolidate. In order to thoroughly respond to plaintiff's opposition, defendants need to gather information concerning certain of plaintiff's claims adn address them in a declaration for the Court. Because of plaintiff's numerous motions for an extension of time to file his opposition brief, defendants' reply has come due at a time when certain individuals involved in this case are out of the office on vacation. Defense counsel Marina Utgoff Braswell will be out of the office from August 7-18 on leave. While defendants have made every effort to prepare the necessary declaration and brief prior to counsel's departure from the office, it simply was not possible to complete it with certain people unavailable for necessary consultation and coordination.

Consequently, this motion for enlargement of time is

1

necessary in order for defense counsel to coordinate federal defendants' response with various agency representatives and to prepare and finish defendants' brief. Defendants regret the need to seek this further extension of time and anticipate that no further extension will be necessary.

By telephone call on August 2, 1995, plaintiff informed defense counsel that this motion will not be opposed.

Accordingly, for the foregoing reasons, federal defendants respectfully request that this motion for enlargement of time be granted,

Respectfully submitted,

__________________________
ERIC H. HOLDER, JR., D.C. BAR #303115
United States Attorney

MARINA UTGOFF BRASWELL, D.C. BAR #416587
Assistant United States Attorney