UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

WILLIAM THOMAS,                         
          Plaintiff                    

     v.                            Civil Action No. 97-0712 (TFH)

CHRISTIAN STANTON, et al.,
          Defendants

MOTION FOR ENLARGEMENT OF TIME

The defendants, by and through counsel, respectfully move this Court pursuant to Rule 6(b), Fed. R. Civ. P., to enlarge the time within which to answer or otherwise respond to the complaint in this matter. Defendants request that the time be extended one business day to and including July 28, 1997. Defendants' counsel contacted plaintiff's counsel about this motion, but she could not reach her in time for filing today.

A response to the complaint is due on July 25, 1997. Defendants fully anticipated that they would be able to submit a response to the complaint today; however, defendants' counsel has not obtained all of the information that she needs from the agency. She has Spoken with the agency counsels about this matter Several times and again today, and agency counsel promised that the undersigned would receive that information by July 28, 1997. Accordingly, based on the foregoing, defendants need one additional business to Submit a response in this matter.

Wherefore, based on the foregoing, the defendants respectfully request that the time for answering or otherwise responding to the complaint be extended to and including July 28, 1997. [1]

Respect fully Submitted,

(signed by SMH)
MARY LOU LEARY, DC Bar #3357485
United States Attorney

Stacy M. Ludwig
STACY M. LUDWIG, D.C. Bar, # 445719
Assistant United States Attorney


[1 Defendants respectfully reserve all defenses available to them under Fed. R. Civ. P. 12(b)(6), including qualified immunity.]


CERTIFICATE OF SERVICE

I hereby certify that the foregoing copy of the motion for enlargement of time HAS been Sent via first class mail, this 25th day of July 1997, addressed to:

Daniel M. Schember, Esq.
Alisa Wilkins, Esq.
Gaffney & Schember
1666 Connecticut Avenue, N.W. Suite 225
Washington D.C. 20009

Stacy M. Ludwig
Assistant United States Attorney
Judiciary Center Building
555 Fourth St., N.W.
Washington, D.C. 20001
(202) 514-7147


UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

WILLIAM THOMAS,                         
          Plaintiff                  

     v.                            Civil Action No. 97-0712 (TFH)

CHRISTIAN STANTON, et al.,
          Defendants

ORDER

UPON CONSIDERATION of the defend ants' motion for enlargement of time and for good cause shown, it is this day of ________, 1997,

ORDERED, that the defendants' motion should be and is hereby granted, and it is further

ORDERED, that defendant shall have until July 28, 1997, within which to answer or other wise respond to the complaint.

UNITED STATES DISTRICT JUDGE

Stacy M. Ludwig
Assistant United States Attorney
Judiciary Center Building
555 4th Street, N.W., Room 10-806
Washington, D.C. 20001

Daniel M. Schember, Esq.
Alisa Wilkins, Esq.
Gaffney & Schember
1666 Connecticut Avenue, N.W. Suite 225
Washington D.C. 20009