UNITED STATES COURT OF APPEALS
DISTRICT OF COLUMBIA CIRCUIT

No. 91-5304                              SEPTEMBER TERM, 1991
                                               CA No. 88-3130
Mary Huddle, et. al.,
                Appellants
                                          RECEIVED
          v.                            NOV 25 1991
                                 CLERK OF THE UNITED STATES
Ronald W. Reagan, et. al.,            COURT OF APPEALS
                Appellees.

MOTION OF APPELLANT WILLIAM THOMAS FOR LEAVE TO FILE OUT OF TIME
OPPOSITION TO FEERAL APPELLEES' MOTION FOR SUMMARY AFFIRMANCE

On November 14, 1991 appellees filed a Motion for Summary Affirmance (Appellees' Motion) in this case. It appears that Appellants' opposition to that motion would be due today. Appellant hereby moves for leave to file their opposition to appellees' Motion on November 27, 1991.

Primarily appellees' motion pivots on the issue of whether appellants raised any "genuine issues that properly can be resolved only by a finder of fact..." Appellees' Motion at 3, citing Hudle memo at 7.

The instant request shoul not be construed as any inddication that appellant views this matter as less than very serious. Simply, the task of researching the legal issues raised by appellees, and organizing the many factual allegations raised in this case into an ordered response -- as necessitated to clearly communicate his position to this Court -- has just proven too great a task for appellant, given his lack of expertise, to accomplish within the allotted time period -- despite the fact that he has continually applied himself to the chore without any days of rest.

1

Wherefore appellant requests that he be permitted to file his opposition on (or before) November 27, 1991.

Respectfully submitted,

William Thomas, appellant
2817 11th Street N.W.
Washington, D.C. 20001

CERTIFICATE OF SERVICE

I, William Thomas, hereby certify that, on November 25, 1991, I served copies of the Motion of Appellant William Thomas for Leave to File Out of Time Opposition to Federal Appellees' Motion for Summary Affirmance upon AUSA Robert Shapiro, by mailing it first class U.S. mail, postage pre-paid to Judiciary Square, 555 4th Street NW, 4th floor, Washington, D.C. 20001, and upon Assistant Corporation Counsel for the District of Columbia, Victor Long by mailing it first class U.S. mail, postage pre-paid to the District Building, 1350 Pennsylvania Avenue, NW, Rm. 314, Washington, D.C.

_________________________
William Thomas, appellant