THOMAS v. REAGAN
USDC Cr. No. 84-3552
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
WILLIAM THOMAS
Plaintiff,
vs. CA No. 84-3552
Judge Louis Oberdorfer
UNITED STATES OF AMERICA, et. al. Magistrate Arthur Burnett
Defendants
PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO AUGUST 25
TO REPLY TO DEFENDANT LINDSEY'S MOTION TO DISMISS
OR FOR SUMMARY JUDGMENT
On August 18, 1986, plaintiff petitioned the Court for an
extension of time in which to respond to defendant Lindsey's Motion
to Dismiss or for Summary Judgment. Calculating that a minimum of
40 hours would be necessary for the completion of his response,
plaintiff fully expected to be filing that document only shortly
before 4:00 p.m. on August 21, 1986.
Also on August 18, 1986, plaintiff spoke by phone with the
Magistrate's chambers and, upon inquiry, was told that no
depositions had as yet been scheduled for defendants Fish, Bangert,
or Robbins.
On Tuesday, August 19, 1986, through intermediaries, plaintiff
learned that the deposition of Manus J. Fish had been scheduled for
9:30 a.m. August 21, 1986. It had been anticipated that "plaintiff
is likely to take some depositions during the week of August 25,
1986" (Federal Defendants' Motion to Alter or Reschedule Date on
which Dispositive Motions Are Due, filed August 13, 1986, p. 1),
and the August 21, 1986 deposition date came as a surprise.
To prepare for the deposition of defendant Fish, it has been
necessary for plaintiff to suspend work on the response to
defendant Lindsey's Motion. Plaintiff reckons a minimum of twenty
hours of work remain before the completion of his response to
defendant Lindsey's Motion. Plaintiff does not expect to be able
to return to that task before noon on August 21, 1986.
Therefore, plaintiff asks the Court to extend the time in
which he may respond to defendant Lindsey's Motion until August 25,
1986.
Respectfully submitted this _____ day
of _________, 1986.
____________________________________
William Thomas, Plaintiff Pro Se
1440 N Street NW, #410
Washington, DC 20005
(202) 462-3542
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