RECEIVED
JUL 31 1984
CLERK U.S. DISTRICT COURT
DISTRICT OF COLUMBIA

Crim. No. 84-255

UNITED STATES OF AMERICA

v.

WILLIAM THOMAS et. al

Now comes defendant William Thomas, through counsel, and moves the court for leave to adopt the motions filed by co-defendant Picciotto in this matter. These motions are for return of property, bill of particulars, suppression of evidence, dismissal of indictment, severence of defendants. As grounds for this motion, defendant states the following:

1. Defendant was arrested on June 6, 1984, and charged with unlawful camping in a national park. Subsequently, the court set July 31, 1984, as the due date for all motions to be filed.

2. Counsel was not appointed to represent the defendant until July 13, 1984. Counsel undertook a previously planned vacation from July 21, 1984 until July 29, 1984.

3. Given the nature of the instant case, any new motions filed by defendant Thomas would be merely duplicative of those already filed.

4. Defendant also wishes to adopt the motion for a jury trial filed by defendant Ellen Thomas.

WHEREFORE, defendant prays that his motion be granted.
Respectfully submitted.

/s/Robert A. DeBerardinis, Jr.
1534 Sixteenth Street, N.W
Washington, D.C. 20036
202-328-0700
Counsel for Defendant Thomas

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing motion was mailed this

31^st day of July 1984 to Assistant U.S. Attorney Pamela Stewart, Federal

Courthouse, Washington, D.C.

Robert A. DeBerardinis, Jr.