UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
WILLIAM THOMAS,                )
              Plaintiff,       )   Civil Action No. 99-0330(SS)
                               )
     v.                        )              FILED
                               )           MAY 5 1999
OFFICER DAVID LOMBARDI         )   NANCY MAYER WHITTINGTON, CLERK
              Defendants,      )       U.S. DISTRICT COURT
_______________________________)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME

The defendant, by and through counsel, respectfully moves this Court pursuant to Rule 6(b)(1), Fed. R. Civ. P., to enlarge the time to answer or otherwise respond to the complaint until May 19, 1999. Plaintiff's counsel consents to this request.

The answer is due on May 4, 1999. Due to the press of other business, the defendant will need more time to respond to the complaint. In particular, during htemonth of March and early April, the undersigned has been preparing for and in trial before this Court in DeLorbe v. Billington, Civil Action 97-1621. During that time period, that trial absorbed almost all of the undersigned's time. Subsequently, the undersigned has been involved in resonding to some serious issues that have arisen in one of her other cases which has taken most of her time in hte last few weeks. She will also have to focus on that case for the next two weeks.

WHEREFORE, based on the foregoing, the defendant respectfully requests that the time for answering or otherwise

1

responding to the complaint be extended to and including May 19, 1999.1

Respectfully submitted,

Wilma A Lweis/SML /s/
WILMA A. LEWIS, DC Bar #358737
United States Attorney

Mark E. Nagle / SML /s/
MARK E. NAGLE, DC Bar #416364
Assistant United States Attorney

Stacy M. Ludwig /s/
STACY M. LUDWIG, DC Bar #447719
Assistant United States Attorney

1 Defendant hereby reserves all defenses available to him under Fed. R. Civ. P. 12(b), including qualified immunity.

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CERTIFICATE OF SERVICE

I hereby certify that the foregoing copy of the motion for enlargement of time has been mailed via first class mail, this 4th day of May 1999, addressed to:

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

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