UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MARY HUDDLE and PHILIP JOSEPH, et. al.,
                Plaintiffs, Pro Se

         versus                       CA 88-3130-JHG
                                      Judge Joyce Hens Green

RONALD WILSON REAGAN, et. al.,

PLAINTIFFS' MOTION FOR AN EXTENSION OF TIME
IN WHICH TO REPLY TO THE MOTIONS OF THE FEDERAL DEFENDANTS
TO DISMISS, AND OF THE DISTRICT OF COLUMBIA
TO DISMISS OR FOR SUMMARY JUDGMENT

William Thomas, on behalf of all plaintiffs, hereby moves for an extension of time, up to and including January 6, 1988.

The grounds for this request are more fully related in an accompanying Memorandum.

A proposed Order is attached.

Respectfully submitted,

//s// W. Thomas

William Thomas
Plaintiff, pro se
1440 N Street, N.W. Apt. 410
Washington, D.C. 20005
202-462-0757



RECEIVED
JAN 3 3 19 PM
'89

U.S. DISTRICT COURT
DISTRICT OF COLUMBIA

MEMORANDUM IN SUPPORT OF
PLAINTIFFS' MOTION FOR AN EXTENSION OF TIME
IN WHICH TO REPLY TO THE MOTIONS OF THE FEDERAL
DEFENDANTS TO DISMISS, AND OF THE DISTRICT OF COLUMBIA
TO DISMISS OR FOR SUMMARY JUDGMENT

At the hearing on December 5, 1988 the Court directed all defendants to file dispositive motions in response to the Complaint by December 21, 1988. Plaintiffs' responses were to be filed by today.

On December 21, 1988 the federal defendants filed a Motion to Dismiss the Complaint. After a brief extension of time, the District of Columbia filed a Motion to Dismiss or for Summary Judgment.

Due to a number of factors unanticipatable by plaintiffs on December 5, 1988 -- including other court business, the hospitalization of a friend, and (due to extended holiday closures) lack of access to clerical devices and library facilities - plaintiffs find themselves unable to meet the scheduled date.

Moreover, the manner in which defendants have chosen to move against this Complaint (e.g. see, Plaintiff's Motion to Strike Federal Defendants' Exhibit 4, filed this date) has raised other difficulties, involving the accumulation of records necessary to set the record straight.

This requested three-day extension of time should enable plaintiffs to prepare a reasonably complete and accurate reply to all defendants' motions.

Plaintiffs stipulate that, if less time is required, they will file prior to January 6th, and, God willing and the U.S. Attorney's security forces permitting, plaintiffs' pleadings will be hand delivered to opposing counsels at their offices.

1

On December 5, 1988 Mr. Martinez represented that he has "been dealing with Mr. Thomas for years." He knows what this is all about, and will discover no great surprises in plaintiffs' ultimate filings. Likewise the motion filed on behalf of the District of Columbia indicates that Mr. Burger also knows what is
going on.

Therefore, this short requested extension will not prejudice any defendants.

WHEREFORE, plaintiffs request the Court to sign the accom-panying Order.

Respectfully submitted,

//s// W. Thomas
William Thomas
Plaintiff, pro se
1440 N Street, N.W. Apt. 410
Washington, D.C. 20005
202-462-0757

CERTIFICATE SERVICE

I William Thomas, hereby state that, on this 3rd day of January, 1989 I caused a copy of the foregoing Plaintiffs' Motion For An Extension Of Time In Which To Reply To The Motions Of Federal Defendants To Dismiss, And Of The District Of Columbia To Dismiss Or For Summary Judgment, together with a supporting Memorandum, to be hand-delivered to the office of Assistant U.S. Attorney Michael Martinez, at Judiciary Square, 555 4th Street, N.W., Washington, D.C. 20001, and to the office of Assistant Corporation Counsel for the District of Columbia, Arthur Burger, at 1350 Pennsylvania Avenue, N.W., Washington, D.C..

//s//W. Thomas
William Thomas

2

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MARY HUDDLE and PHILIP JOSEPH, et. al.,
                Plaintiffs, Pro Se

         versus                       CA 88-3130-JHG
                                      Judge Joyce Hens Green

RONALD WILSON REAGAN, et. al.,

ORDER

Upon consideration of plaintiff's Motion For An Extension Of Time In Which To Reply To The Motions Of Federal Defendants To Dismiss, And Of The District Of Columbia To Dismiss Or For Summary Judgment, and the Memorandum in support thereof, this ________
day of , 1989, it is hereby:

ORDERED that plaintiffs' Motion be and hereby is granted, and plaintiffs shall have up to and including January 6, 1989 within which to file their Replies to the Motions of the Federal Defendants to Dismiss, and the District of Columbia Defendants to Dismiss or for Summary Judgment.

 

UNITED STATES DISTRICT COURT JUDGE

COPIES OF THIS ORDER SHOULD BE ADDRESSED TO:

AUSA Michael Martinez
Judciary Square
555 4th Street, N.W.
Washington, D.C. 20001

Arthur Burger
Assistant Corporation Counsel
for the District of Columbia,
1350 Pennsylvania Avenue, N.W.,
Washington, D.C.