Filed
MAY 8 1986
Alas. Neuman, Clerk

DISTRICT OF COLUMBIA COURT OF APPEALS

CA 1125-86
Appeals Ct. No. 86 - 0678


DISTRICT OF COLUMBIA COURT OF APPEALS

WILLIAM THOMAS,Plaintiff Pro Se;
White House Antinuclear vigil;
Peace Park Antinuclear Vigil
:
1440 N Street NW #410
Washington, DC 20005
Plaintiffs /Appellants

Versus

WASHINGTON TIMES;
Colonel Bo Hi Pak; Bo Hi
Arnaud de Borchgrave
3600 New York Ave. NE
Washington, DC
Defendants /Appellees


MOTION FOR SUMMARY REVERSAL

Pursuant to Rule 27(a)(b) of the District of Colombia Court of Appeals, and Sills v. Beareau of Prisons USDC 84-5844, filed May 14, 1985, Appellant asks that the Court remand this case back to Superior Court for discovery and trial because Judge Hannon provided no judicial notice as to the reason(s) for dismissal.

The record shows on face of the pleadings that there was good cause for discovery and trial. As Sills provides, dismissal by fiat is not acceptable -- there must be more than a pro forma dismissal based on appellees' filings, without explanation for dismissal.

Therefore, appellant asks the Court not waste its own and all parties' hereto time on lengthy appeal proceedings, and instead provide appellants with summary reversal and reinstate this case for hearing in D.C. Superior Court.

This 8th day of May, 1986.

/s/W. Thomas
WILLIAM THOMAS, Appellant Pro Se
1440 N Street NW #410
Washington, DC 20005
(202) 462-3542


DISTRICT OF COLUMBIA
COURT OF APPEALS
CA 1125-86
Appeals Ct. No. 86 - 0678


DISTRICT OF COLUMBIA COURT OF APPEALS

WILLIAM THOMAS,Plaintiff Pro Se;
White House Antinuclear vigil;
Peace Park Antinuclear Vigil
:
1440 N Street NW #410
Washington, DC 20005
Plaintiffs /Appellants

Versus

WASHINGTON TIMES;
Colonel Bo Hi Pak; Bo Hi
Arnaud de Borchgrave
3600 New York Ave. NE
Washington, DC
Defendants /Appellees


ORDER

Upon consideration of appellant's Motion for Summary Reversal and any response thereto, it is hereby

ORDERED that D.C. Superior Court Judge Hannon's Dismissal be reversed, and this case shall be remanded back to the Superior Court of the District of Columbia, Civil Division, for discovery and trial.

This ____ day of _______________________, 1986.

/s/___________________________________

Judge, Appeals Court


CERTIFICATE OF SERVICE

BY MAIL

I hereby certify that a true and correct copy of the foregoing Motion for Leave to Extend Time to File Civil

Appeal Statement; Motion for Summary Reversal; and Appellants' Brief for Summary Reversal with proposed orders was sent, certified mail, to the defendants at the following addresses:

John P. Brown, Registered Agent
News World Communications, Inc.
3600 New York Avenue NE
Washington, DC 20002 :

Washington TIMES
Bo Hi Pak
Arnaud de Borchgrave
(Appellees)

Allen V. Farber and Lucinda J. Bach
Scwalb, Donnenfeld, Bray & Silbert
1025 Thomas Jefferson St. NW, Suite 300 East
Washington, DC 20007
(Counsel for Defendants (now Appellees)

This 8th day of May, 1986.

/s/W. Thomas
William Thomas, Appellant Pro Se
1440 N Street NW #410
Washington, DC 20005
(202) 462-3542


DISTRICT OF COLUMBIA COURT OF APPEALS

DISTRICT OF COLUMBIA
COURT OF APPEALS
REC'D MAY 8 1986
Clerk

Appeals Ct. No.1125-86

WILLIAM THOMAS,Plaintiff Pro Se;
White House Antinuclear vigil;
Peace Park Antinuclear Vigil
:
1440 N Street NW #410
Washington, DC 20005
Plaintiffs /Appellants

Versus

WASHINGTON TIMES;
Colonel Bo Hi Pak; Bo Hi
Arnaud de Borchgrave
3600 New York Ave. NE
Washington, DC
Defendants /Appellees


APPELLANT'S BRIEF FOR SUMMARY REVERSAL

Certificate required by Rule 28(a)(1) of the General Rules of the District of Columbia Court of Appeals:

I, William Thomas, Appellant pro se, hereby certify that the following listed parties were captioned in this case in the District Court:

William Thomas
1440 N Street NW, #410
Washington, DC 20005

White House Antinuclear Vigil
(Concepcion Picciotto
P.O. Box 4931
Washington, D.C. 20008)

Peace Park Antinuclear Vigil
(Ellen Thomas]
P.O. Box 27217
Washington, D.C. 20038
Plaintiffs (now Appellants)

Washington Times
3600 New York Avenue NE
Washington, D.C.
News World Communication, Inc. (same address)
Arnaud deBorchgrave (same address)
Bo Hi Pak (same address)
Defendants (now Appellees)

Schwalb, Donnefeld, Bray and Silbert
(Allen V. Farber and Lucinda J. Bach)
Suite 300 E, 125 Thomas Jefferson Street NW
Washington, DC 20007

This appeal is taken in good faith, and appellant is ready to take all steps necessary to complete this appeal to the best of my knowledge and financial limitations.

William Thomas, Appellant Pro Se

TABLE OF CONTENTS

Page Number


Table of Cases 2

Statement of Issues 2

Statement of the Case 3

Argument 3

Conclusion 4

Attachment A - Opposition to the Motion to Dismiss 5-10

7. Attachment B - Certified Receipt Bo Hi Pak 11-12

8. Attachment C - Certified Receipt Arnaud deBorchgrave 13-14

9. Attachment D - Certified Receipt John T. Brown (News World Communications Inc. registered agent) 15-16

10. Attachment E - Judge Hannon's Order 17

TABLE OF CASES

*Bielitski v. Obadiak, 15 Sask 153; 65 DLR 627 (1922)

Brown v. DuFrey, 134 NE2d 469, 472-474; 1 NY2d 190

*Clark v. Associated Retail Credit Men, 70 App D.C. 986; 105 F2d 65

Great Atlantic and Pacific Tea Co. v. Roch, 160 Md 189; 153 A 22 (1931)

Haines v. Kerner, 404 US 519 (1972)

Halberstam v. Welch 705 F2d 477

*Nickerson v. Hodges, 146 La 753; 84 So. 37 (1920)

Rosen & Associates, Inc. v. Huritz, 465 A2d 1114 (DC App 1983)

*Sills v. Bureau of Prisons, USDC CA 84-03739; opinion filed May 14, 1985

*Terminiello v. Chicago, 337 US 4, 5 (1948)

Wilkinson v. Downtown, 2 QBD 57 (1897)


STATEMENT OF ISSUES

A. Whether appellant's Complaint was improperly served

B. Whether appellant's Complaint stated a claim

C. Whether Superior Court judge failed to STATE A REASON FOR DISMISSAL


STATEMENT OF THE CASE

1. On February 6, 1986, appellant filed a complaint charging the intentional infliction of emotional distress, conspiracy, and defamation. It was assigned to Judge Hannon, D.C. Superior Court.

2. Appellees have admitted the article was written, and did not deny the facts as appellant presented them, but maintained that appellee had "failed to state a clam." There was no opinion and no finding of fact.

3. The Court granted appellee's Motion to Dismiss.

4. Appellees were thus relieved of the burden of a responsive answer to the Complaint.


ARGUMENT

Appellants have been peacefully engaged, consistently and over a long period of time, in front of the White House, exercising the socially beneficial and Constitutionally protected activities of free speech and petitioning for redress of grievances.

Appellees' agent, Steve Masty, allegedly by prearrangement participated in an attempt to disrupt and defame appellants' legitimate and privileged activity.

Appellants' claim that the motive of appellees was to further their own political interests. The merits of appellants claims have not received even cursory examination.

If appellants' claims are well founded, appellees' actions are outrageous. Certainly for the Court to allow a public newspaper, an instrument capable of influencing public opinion on a broad scale, to glorify an attack on harmless individuals pursuing legitimate social intercourse, would threaten the very fabric of individual freedom of expression and democracy. If a public carrier such as the Washington TIMES may with impunity falsely portray dedicated individuals as drunks, bums, or lunatics, or expose them to public hatred and the likelihood of physical assault by false representing peaceful non-partisans as "screwball" "leftists," appellants suggest such a situation would place the expresser of a minority opinion at the mercy of any poison pen writers with the backing of a powerful publication machine, signaling the breakdown of civilization, and should not be permitted by the Court.


CONCLUSION

If appellant failed to make service properly, the Court should have noted that fact and allowed for correction of the error.

If appellant failed to state a claim, the Court should have allowed for the appellant, proceeding pro se, to amend his Complaint.

The Court has failed to provide appellants with any explanation for dismissal.

Respectfully submitted this 8th day of May, 1986.

William Thomas, Appellant Pro Se
1440 N Street N #5410
Washington, DC 20005
(202) 462-3542


SUPERIOR COURT OF THE DISTRICT OF COLUMIA

CA 1125-86

WILLIAM THOMAS, Plaintiff Pro Se
White House Antinuclear Vigil,
Peace Park Antinuclear Vigil,

Plaintiffs

-versus-

WASHINGTON TIMES,

Bo Hi Pak, Arnaud de Borchgrave,
Defendants.


OPPOSITION TO DEFENDANT'S MOTION TO DISMISS
AND TO QUASH SERVICE OF PROCESS

Counsel purports that service of process was not effected in accordance with Rule 4. See Defendant's Motion to Dismiss and to Quash Service of Process, filed March 12, 1986 ("DMD").

First, defendants note that plaintiff ("Thomas") has sued the Washington Times, Inc. ("TIMES") and that no such corporation exists, and notes that Thomas has identified Mr. Pak and Mr. de Borchgrave as affiliate agents of the defendant TIMES.(Dim Memo p. 1.)

A. Sufficency of Service of Process

Rule 4 (c) (ii) "Service": "By mailing a copy of the summons and Complaint to the persons to be served by registered or certified mail, return receipt requested." ( Exhibit A, 'this Demo.)

Rule 9(a): "It is not necessary to aver the capacity of a party ... to be sued or the authority ... in a representative capacity or the legal existence of an organized association of persons that is made a party except to the extent required to show the jurisdiction of the Court."

Defendants note that the corporate entity which publishes the TIMES is News World Communications, Inc.,

Thomas hereby certifies that, pursuant to Rule 4(c)(ii), he has served upon that registered agent a copy of the Complaint, and a Summons, by certified mail.

Under the Opposition heading (DMD Memo at 3), counsel cites generally Rosen and Associates, Inc. v. Hurwitz, 465 A2d 1114 (DCApp 1983). In that case the Court reversed not because "a receptionist ... is not necessarily authorized to accept service of process," as it might appear defendants suggest. Rather judgment in that matter revolved upon the principle that'

"Even if trial court was correct in striking defendants' Motions to Quash Service of Process ... trial court could not enter a default judgment against those defendants.... Entry of a judgment for damages ... without a hearing, was error...." (ibid. at 1115)

: Thomas, seeking to be an honest man, is therefore poor. Rightly he has been given leave by this Court to proceed in forma puperis and cannot afford a process server. Additionally the U.S. Marshall's Service is under a heavy case load, and Thomas would submit Rule 4(c)(ii) provides a simple but efficient method of service, which to the best of Thomas' knowledge he has utilized to facilitate an expeditious litigation of this matter. See Haines v. Kerner, 404 US 519 (1972). Moreover, recent decisions in the Federal Appeals Court in this District have reaffirmed the jurisprudential tradition of any civilized democracy that "meaningful access to the courts" shall not be denied for reasons of indigency, or otherwise financially incapacitate individuals. See Sills v. Bureau of Prisons' USEC App (1984)

B. Plaintiff has stated a substantial claim:

1. "extreme and outrageous" conduct on the part of defendants by means of their newspaper, the Washington TIMES,

(a) to "further the purpose or attempting to justify and aggrandize defendants' political opposition to plaintiffs' high-profile 24-hour year around antinuclear vigil ... in Lafayette Park under duly approved PERMIT of the US (National Park Service J" (Complaint para. 4):

(b) "Defendants' agent Steve Masty and several unknown individuals from a group calling itself Young Americans for Freedom (now YAF) had a meeting of the minds and decided to conduct a 'raid' on plaintiffs and their property." (ibid. pare. 5);

(c) "The 'Washington Times virtually 'cooked up' a story by sending Mrasty to report on and(/or) participate in an assault on the plaintiffs and their property as abovesaid, and to distribute to the Public an intentional, wrongful, malicious, libelous, and defamatory representation of that morning's (July 4, 1985) events.

"Allegedly libelous matter is 'defamatory' not only if it brings a party into hatred, contempt, or ridicule by asserting some moral discredit on his part, but also if it tends to make him be shunned or avoided, or deprived of the friendly association of a considerable number of respectable members of the community, though it imputes no moral terpitude to him." Brown v. DuFrey, 134 NE 2d 469, 472-474: 1 NY2d 190.

d. Incorporating pare. a, b and c, plaintiff claims he was irreparably damaged in his right to expression through damage to his signs.

e. Incorporating d, plaintiffs claim their property was damaged

f. Incorporating a, b, c, d and e plaintiff claims to have suffered intentional infliction of emotional injury.

2. This is not, by any means, the only occasion upon which the TIMES has acted "intentionally or recklessly" to distort the truth with respect to what they should have known to be activity considered essential to a democratic society, and protected by United States statute, and UPS permit.

(a) Defendants have falsely, maliciously, intentionally, and libelously represented Thomas and/or his legal activities as "childish willfulness," "delusions of the insane," "vague gibberish," and "the screwball left." In publishing this willful misrepresentation defendants have published a false image of Thomas as a "bum," causing him alienation from a substantial portion of the populace, and condoning and encouraging a "continuous menace to their lives and well-being in pursuit of their lawfully permitted activities" which has directly and proximately caused Thomas to suffer the infliction of emotional distress.

(b) Further, the TIMES has published other material with bearing on this case not attached to the Complaint

(c) Incorporating (a) and (b) supra, Thomas avers that the aforesaid has combined to disrupt, demean' and interfere with his chosen profession of communicating a message of broad public concern to Thomas' irreparable injury.

3. Citing Restatement (2d) of Torts (1965) Section 46 at 73 (DMD at 5), counsel correctly states that defendants' liability rest upon whether conduct is "utterly intolerable in a civilized society."

"The vitality of civil and political institutions in our society depends on free discussion. As Chief Justice Hughes wrote in DeJonge v. Oregon, 299 US 165, it is only through free debate and free exchange of ideas that government remains responsive to the will of the people and peaceful change is effected. The right to speak freely and to promote diversity of ideas and programs is therefore one of the chief distinctions that sets us apart from totalitarian regimes.... Accordingly a function of free speech under our system of government is to invite dispute. It may well serve its high purpose when it induces a condition of unrest, creates dissatisfaction with conditions as they are, or even stirs people to anger. Speech is often provocative and challenging. It may strike at prejudices and preconceptions and have profound unsettling effects as it presses for acceptance of an idea. That is why freedom of speech ... is ... protected ... unless shown likely to produce a clear and present danger of a serious substantive evil that rises far above public inconvenience, annoyance, or unrest.... There is no room under our Constitution for a more restrictive view. For the alternative would lead to standardization of ideas either by ... dominant political or community groups." Terminiello v. Chicano, 337 US 4, 5 (1948).

Restatement (2d) of Torts Section 46 makes certain other representations, e.g.:

"The law is still in a stage of development, and the ultimate limits of this tort are not yet determined. (See also Magruder, Mental and Emotional Disturbance in the Law of Torts 47 Harvard Law Review 1033, 1053 (1938)."

5. Even assuming, arguendo, that defendants' public allegations with respect to plaintiffs' sanity were true, they would still be liable for malicious misrepresentations which resulted in plaintiffs' emotional distress:

Restatement (2d) of Torts, Section 46 at 75.)

A knows that B, a Pennsylvania Dutch farmer, is extremely supersitious and believes in witchcraft. In order to force B to sell A his farm A goes through the ritual of putting a "hex" on the farm, causing B to believe it is bewitched so that crops will not grow on it. B suffers severe emotional distress and resulting illness. A is subject to liability to B for both." (Ibid. at 75, 76.)

6. Counsel cites Walden v. Covington (DMD Memo at 5), an action which had been dismissed against the widow of a decedent plaintiff who had sought to assume the litigation upon his demise. The Court dismissed upon the rationale that: "the deceased bore the pain and suffering and he is the only one who should be compensated. He can't take it with him." (Ibid. at 1075)

Notwithstanding, Walden v. Covington affirms the decision in Wilkinson v. Downton, 2 QBD 57 (1897), Dickerson v. Hodges, 146 La. 735 84 So. 37 (1920), Bielitski v. Obadiak, 15 Sask. 153, 65 DLR 627 (1922), and Great Atlantic and Pacific Tea Co. v. Roch, 160 Md. 189, 153 A. 22 (1931), et al.

"The actor's lack of privilege of 'just cause or excuse' is another element that must be assessed in determining whether his acts are so outrageous that harmful intent can be presumed." Walden v. Covington, 415 A. 2d 1077. See also Clark v. Retail Credit Men, 70 App D.C. 187-88, et al.

7. Erroneously counsel states "(p)laintiff made no effort to describe the actions which they claim constituted a 'raid.'" (DMD Memo at 4) While the article (DMD Memo exhibit A) speaks for itself, plaintiff alleges that it contains intentionally false, libelous, defamatory material, but mainly that the Washington TIMES "cooked up" or acted in furtherance of a "media event" to create a vehicle through which to push the very IDEA of Masty's story, namely that plaintiff was a "screwball" or "leftist."

"The extreme and outrageous character of the conduct may arise from an abuse by the actor of a position, or a relation with the other which gives him actual or apparent authority over the other, or power to affect the interests." (Restatement (2) of Torts, Section 48 at 80.)

Defendants' ability to disseminate to a broad spectrum of the public an intentionally defamatory image of plaintiffs' activities would certainly seem a "power to affect his interests."

"A common carrier or other public utility is subject to liability ... inflicted by the utility's servants while otherwise acting within the scope of their employment." (Ibid. at 81.)

"The rule stated in this section goes further and makes such a defendant liable for conduct which falls short of extreme outrage." (Ibid.)

C. Plaintiffs state a succinct claim for civil conspiracy.

To support his claim, Thomas alleges seven underlying torts:

1. intentional infliction of emotional distress:

2. libel:

3. deprivation of association:

4. interference with chosen professional activities or religion / (politics?):

5. disruption and malicious defamation of plaintiffs' lawful activities with the intention to interrupt, interfere

with, or terminate those activities:

6. damage to plaintiffs' property: and

7. incitement of public hatred, ridicule, and humiliation.

D. For harm resulting to a third person from the tortious conduct of another, one is subject to liability if he:

1. does a tortious act in concert with the other or pursuant to a common design with him (Halberstam v. Welch, 705 F2d 477), or

2. "knows that the other's conduct constitutes a breach of duty and gives substantial assistance or encouragement to the other as to conduct himself" (ibid.), or

3. "gives substantial assistance to the other in accomplishing a tortious result and his own conduct, separately considered, constitutes a breach of duty to the third person" (ibid.);

4. "in sum, we expect that the relationships between the actors and the actions (e.g. the proximity in time and place of the acts, and the duration of the actors' joint activity) are relevant in inferring an agreement in a civil conspiracy action. There may well be other significant factors in individual cases." (Ibid. 481)

5. "Suggestive words may also be enough to create joint liability when they plant the seeds of action and are spoken by a person in an apparent position of authority." (Ibid.)

The "seed" of Masty's article bears fruit after the fact, feeding the insanity of those who would seek to enforce their will on the innocent through force and violence

PLAINTIFF STANDS READY TO AMEND HIS COMPLAINT UPON REQUEST.

Upon consideration of the foregoing, any opposition thereto, and the Amended Complaint filed herewith, plaintiffs move this Court to moot defendants' "Motion to Dismiss and to Quash Service of Process."

Respectfully submitted,

/s/William Thomas
William Thomas, Plaintiff Pro Se
1440 N Street NW #410
Washington, DC 20005
(202) 462-3542

SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
CIVIL DIVISION

CIVIL ACTION NO.________________

William Thomas, et al Plaintiff (s)

vs.

Washington Times, et al

Defendant (s)

AFFIDAVIT OF SERVICE BY REGISTERED / CERTIFIED MAIL

I, William Thomas, under oath do hereby state the following:

That my aqe and birth, date are as follows 39 3/20/47___________________________

That my residentia1 or business address is 1440 N Street NW Washington, D.C. 20005 Apt 410_____________

That a copy of the summons and complaint was mailed by the affiant, to the above named defendant _______ (Wahington Times) Bo Hi Pak , by registered/certified mail.

( name of defendant )

That the return receipt attached hereto was signed by ______________________________________________, the Defendant herein, or ______H. Cavanaugh______, a person of suitable age and discretion employed therein at the defendant's usual place of work, and the said receipt shows the date of delivery as ___2 - 11 - 86_______

If the return receipt does not purport to be signed by the party named in the summons, then state specific facts from which the Court can determine that the person who signed the receipt meets the appropriate qualifications for receipt of process as required by Superior Court Rule 4 (d).

SPECIFIC FACTS

/s/W. Thomas

Signature

Subscribed and Sworn to before me this _______day of ______________________________

SUPERIOR COURT OF THE DISTRICT OE COLUMBIA
CIVIL DIVISION

William Thomas, et al
Plaintiff (s) CIVII. ACTION NO.________________

vs.

Washington Times, et al
Defendant (s)


AFFIDAVIT OF SERVICE BY REGISTERED / CERTIFIED MAIL

I, William Thomas, under oath do hereby state the following:

That my aqe and birth, date are as follows 39 3/20/47
That my residentia1 or business address is 1440 N Street NW Washington, D.C. 20005 Apt 410

That a copy of the summons and complaint was mailed by the affiant, to the above named defendant _______ (Wahington Times) Arnad DeBerchgrave , by registered/certified mail.
( name of defendant )

That the return receipt attached hereto was signed by ______________________________________________, the Defendant herein, or ______H. Cavanaugh______, a person of suitable age and discretion employed therein at the defendant's usual place of work, and the said receipt shows the date of delivery as ___2 - 12 - 86_______

If the return receipt does not purport to be signed by the party named in the summons, then state specific facts from which the Court can determine that the person who signed the receipt meets the appropriate qualifications for receipt of process as required by Superior Court Rule 4 (d).

SPECIFIC FACTS

/s/W. Thomas

Signature

Subscribed and Sworn to before me this _______day of ______________________________

SUPERIOR COURT OF THE DISTRICT OE COLUMBIA
CIVIL DIVISION

William Thomas, et al
Plaintiff (s) CIVII. ACTION NO.________________

vs.

Washington Times, et al
Defendant (s)

AFFIDAVIT OF SERVICE BY REGISTERED / CERTIFIED MAIL

I, William Thomas, under oath do hereby state the following:

That my aqe and birth, date are as follows 39 - 3/20/47
That my residentia1 or business address is 1440 N Street NW Washington, D.C. 20005 Apt 410

That a copy of the summons and complaint was mailed by the affiant, to the above named defendant _______ John P. Brown___________________________, by registered/certified mail.
( name of defendant )

That the return receipt attached hereto was signed by ______________________________________________, the Defendant herein, or ______H. Cavanaugh______, a person of suitable age and discretion employed therein at the defendant's usual place of work, and the said receipt shows the date of delivery as ___3 - 26 - 86_______

If the return receipt does not purport to be signed by the party named in the summons, then state specific facts from which the Court can determine that the person who signed the receipt meets the appropriate qualifications for receipt of process as required by Superior Court Rule 4 (d).

SPECIFIC FACTS

/s/W. Thomas

Signature
Subscribed and Sworn to before me this _______day of ______________________________

SUPERIOR COURT OF THE DISTRICT COLUMBIA CIVIL DIVISION
Civi1 Action No. 1125-86

William Thomas, et al.,

Plaintiffs,

vs.

Washington Times Inc.,

Defendant.

ORDER

Upon consideration of the Defendant's Motion to dismiss, and Memorandum in support thereof and Plaintiff's opposition thereto, it is, this 3rd day of April, 1986,

Ordered that the Complaint against the Washington Times, Inc. be and it hereby is, dismissed in its entirety.

/s/ Joseph Hannon
JUDGE OF THE SUPERIOR COURT

MAILED APR 9 1986
Judge Hannon

cc:
Mr. William Thomas
Apartment 410
1440 N Street N.W.
Washington, D.C. 20005

Lucinda J Bach, Esquire
Alen V. FRBER, Esquire
Schwalb, Donnenfeld, Bray & Silbert
Suite 300 E
1025 Thomas Jefferson Street, N.W.
Washington,D.C. 20007

FILED
APR - 9 1986

CERTIFICATE OF SERVICE

BY MAIL

I hereby certify that a true and correct copy of the foregoing Motion for Leave to Extend Time to File Civil

Appeal Statement; Motion for Summary Reversal; and Appellants' Brief for Summary Reversal with proposed orders was sent, certified mail, to the defendants at the following addresses:

John P. Brown, Registered Agent
News World Communications, Inc.
3600 New York Avenue NE
Washington, DC 20002 :

Washington TIMES
Bo Hi Pak
Arnaud de Borchgrave
(Appellees)

Allen V. Farber and Lucinda J. Bach
Scwalb, Donnenfeld, Bray & Silbert
1025 Thomas Jefferson St. NW, Suite 300 East
Washington, DC 20007
(Counsel for Defendants (now Appellees)

This _8th day of May, 1986.

/s/ W. Thomas

William Thomas, Appellant Pro Se

1440 N Street NW #410

Washington, DC 20005

(202) 462-3542

DISTRICT OF COLUMBIA COURT OF APPEALS

DISTRICT OF COLUMBIA
COURT OF APPEALS
REC'D MAY 8, 1986

WILLIAM THOMAS, Plaintiff Pro Se;

White House Antinuclear Vigil;

Peace Park Antinuclear Vigil:

1440 N Street NW #410

Washington, DC 20005

Plaintiffs /Appellants CA 1125-86

versus

WASHING,TON TIMES;

Colonel Bo Hi Pak;

Arnaud de Borchgrave

3600 Ned }ork eve. NE Appeals Ct. No.

Washington, DC

Defendants / Appellees )

MOTION FOR LEAVE TO EXTEND TIME

TO FILE CIVIL APPEAL STATEMENT

-

On 8th of May, 1986, appellant filed Motion for Summary Reversal. Appellant prays this Court will grant appellant leave to extend time to file Civil Appeal Statement (ordinarily due within 15 days of filing Notice of Appeal) until appellant's Motion for Summary Reversal has been decided.

This 8th day of May, 1986.

/s/ W. Thomas_________________

William Thomas, Appellant Pro Se

1440 N Street NW, #410

Washington, DC 20005

(202) 462-3542

DISTRICT OF COLUMBIA COURT OF APPEALS

VIILIAN THOMAS, Plaintiff Pro Se;

White House Antinuclear Vigil;

Peace Park Antinuclear Vigil:

1440 N Street NW #410

Washington, DC 20005

Plaintiffs / Appellants CA 1125-86

Appeals Ct. No.

versus

WASHINGTON TIMES;

Colonel Ro Hi. Pak;

Arnaud de Borchgrave

3600 Den fork Ave. NE

Washington, DC

Defendants / Appellees

ORDER

Upon consideration of appellant's Motion for Leave to Extend Time to File Civil Appeal Statement, and any response thereto, it is hereby

ORDERED that appellant shall be granted leave to extend time to file Civil Appeal Statement until after decision on appellant's Motion for Summary Reversal.

This ___ day of _________________________, 1986.

_____________________________________

Judge, Appeals Court

CERTIFICATE OF SERVICE

BY MAIL

I hereby certify that a true and correct copy of the foregoing Motion for Leave to Extend Time to File Civil

Appeal Statement; Motion for Summary Reversal; and Appellants' Brief for Summary Reversal with proposed orders was sent, certified mail, to the defendants at the following addresses:

John P. Brown, Registered Agent

News World Communications, Inc.

3600 New York Avenue NE

Washington, DC 20002:

Washington TIMES

Bo Hi Pak

Arnaud de Borchgrave

(Appellees)

Allen v. Farber and Lucinda J. Bach

Scwalb, Donnenfeld, Bray & Silbert

1025 Thomas Jefferson St. NW, Suite 300 East

Washington, DC 2007

(Counsel for Defendants (now Appellees))

This 8th day of May, 1986.

/s/ W. Thomas__________________

William Thomas, Appellant Pro Se

1440 N Street NW #410

Washington, DC 20005

(202) 462-3542


Listing of Cases

Proposition One

Peace Park | People