UNITED STATES COURT OF APPEALS
FOR THE DISTRICT OF COLUMBIA CIRCUIT

UNITED STATES 0F AMERICA	

        v.		                        Criminal No. 87-64

ELLEN THOMAS

MOTION FOR EXTENSION OF TIME WITHIN WHICH TO FILE RESPONSE
TO GOVERNMENT'S MOTION FOR SUMMARY REVERSAL

The Defendant, Ellen Thomas, through counsel, respectfully requests, pursuant to U.S. Appeals D. C. Rule 6(b), that this Court extend the time period within which to file his response to Government's Motion For Summary Reversal until August 7, 1987.

In support of this motion,counsel states:

1. The Government served its Motion for Summary Reversal by mailing a copy thereof to counsel on July 21,1987.

2. Counsel did not receive the Government's motion until July 24, 1987.

3. Because counsel has been involved in extensive preparations for a criminal trial in D.C. Superior Court set for July 30, 1987, counsel will not be able to respond to the government's motion within seven days after receipt of Service.

WHEREFORE, Defendant respectfully requests that this Court grant this Motion for Extension of Time Within Which to File Response to Government's Motion for Summary Reversal and extend the time period for such filing until August 7, 1987.

Respectfully submitted,

ROBERT M . HURLEY, # 403467
Attorney for Ellen Thomas
GEORGETOWN CRIMINAL JUSTICE CLINIC
25 E Street, N. W. Second Floor
Washington, DC 20001
( 202 ) 662-9575

CERTIFICATE OF SERVICE

This is to certify that a copy of the foregoing Motion has been personally served upon John D. Bates, United States Assistant Attorney, 555 Fourth Street, N.W., Washington, DC 20001, on this 30th of July , 1987.

ROBERT M. HURLEY