United States v. Rainbow

                                   :              FILED
UNITED STATES OF AMERICA,              96 MAR 7  AM10:33     
     Plaintiff,

                  vs.                  CASE NO. 96-183-Civ-J-20

THE RAINBOW FAMILY, etc., et al.,
     Defendants.

Pursuant to the Federal Rules of Civil Procedure and the Local Rules of this Court, John Koessler, who may be the person identified as "John" in the complaint filed in this action by the United States, moves this Court for an order extending for fourteen (14) days the time for him to file his answer or to file motions under Rule 12 of the Federal Rules of Civil Procedure.

In support of John Koessler's motion, the undersigned counsel would show the Court:

(1) John Koessler was only able to obtain the legal services of the undersigned counsel late Thursday, February 29, 1995.

(2) John Koessler is still attempting to obtain the services of counsel within the Midddle District of Florida for purposes of complying with Local Rule 2.02(a) [1]

(3) The United States of America does not oppose the extension, for fourteen (14) days, of time within which John Koessler must answer or move under Rule 12. Anjali Ashley, Esq., in the Civil Division of the United States Department of Justice, in Washington, D.C., confirmed to the undersigned counsel in a telephone conference on Wednesday, March 6, 1996, that the United States had no objection to a fourteen (14) day extension.

WHEREFORE John Koessler respectfully prays that the Court grant the Order Extending Time, in the form attached hereto.

Dated: March 6, 1996

Respectfully submitted,

Jay Alan Sekulow * +
James M. Henderson, Sr.* +
Trial Counsel

THE AMERICAN CENTER FOR LAW AND JUSTICE
1000 Thos. Jefferson Street NW Suite 304
Washington, DC 20007
Telephone: (202) 337-2273
Telefax: (202) 337-3167

* Not Admitted This Jurisdiction

+ Special Admission Pursuant to Local Rule 2.02