City of Greenwood, MS v. Peacock Brief Amicus Curiae

    IN THE
UNITED STATES COURT OF APPEALS

FOR THE FOURTH CIRCUIT

NO. 90-1797

CARRIE YOUNG- HENDERSON,

Plantiff- Appellant

vs.
SPARTANBURG AREA MENTAL HEALTH CENTER, et al.,

Defendants- Appellees.

Appeal from the United States District Court 
For the District of South Carolina 

Greenville Division

REQUEST FOR AN EXTENSION OF TIME 
TO FILE APPELLANT'S BRIEF AND APPENDIX

PLEASE TAKE NOTICE that the undersigned appellant's counsel 

hereby moves, for the reasons set forth in the accompanying 

attorney's affirmation, for an order extending the time in which 

appellant is required to serve and file appellant's brief and 

Appendix in the instant appeal from October 9, 1990 to November 9, 

1990.

Respectfully submitted,

JULIUS L. CHAMBERS
October 4, 1990 CHARLES STEPHEN RALSTON

NAPOLEON B. WILLIAMS, JR. 
99 Hudson Street 
16th Floor
New York, New York 10013 
Tel: (212) 219-1900

Attorneys for Appellant



IN THE
UNITED STATES COURT OF APPEALS

FOR THE FOURTH CIRCUIT

NO. 90-1797

CARRIE YOUNG- HENDERSON,

Plantiff- Appellant

vs.
SPARTANBURG AREA MENTAL HEALTH CENTER, et al.,

Defendants- Appellees.

Appeal from the United States District Court 
For the District of South Carolina 

Greenville Division

AFFIRMATION

NAPOLEON B. WILLIAMS, JR., an attorney duly authorized to 

practice law in the Court of Appeals for the Fourth Circuit, now 

comes and makes the following attorney's affirmation in support of 

the motion for an extension of time from October 9, 1990 to 

November 9, 1990 in which to file appellant's brief and Appendix:

1. First, under the briefing order of this Court, the

appellant's brief and Appendix are scheduled to be filed on October 
9, 1990.

2. This is an appeal from an action prosecuted pro se in the 

district court below.

3. This Court mailed the requisite forms for docketing the 

case to Judith Reed, an attorney in this office who duly filed the 

Docketing Statement with an order for the transcript in this case.



4. Ms. Reed, however, is no longer employed in this office 

but is on a leave of absence, as of three weeks ago, working for 

the City of New York on its Redistricting Commission.

5. I received the papers in this case this week. I have not 

had a chance to go through the files of this case or to obtain the 

transcript or to reach the appellant to clarify the scope of the 

appeal or to prepare appellant's brief and Appendix.

6. In light of the above, I have filed this reguest for an 

extension of time in which to file appellant's brief and Appendix 

from October 9, 1990 to November 9, 1990.

7. Counsel for defendants- appellees, E. Leigh Mullikin, has 

consented, in a telephone conversation at 11:30 a.m. today, to the 

granting of this motion for an extension of time.

NAPOLEON B. WILLIAMS, JR., Esq.

October 4, 1990



IN THE
UNITED STATES COURT OF APPEALS

FOR THE FOURTH CIRCUIT

NO. 90-1797

CARRIE YOUNG- HENDERSON, 

vs.
Plantiff- Appellant

SPARTANBURG AREA MENTAL HEALTH CENTER, et al.,
Defendants- Appellees.

Appeal from the United States District Court 
For the District of South Carolina 

Greenville Division

CERTIFICATE OF SERVICE

I, Napoleon B. Williams, Jr., do hereby certify that I have 

this day served a copy of the within and foregoing Request for an 

Extension of Time in Which to File Appellant's Brief and Appendix 

upon counsel for the appellees by placing a copy of same in the 

United States mail, properly addressed and with the correct amount 

of postage affixed thereto, as well as faxed the same, and sending 

to said counsel at the address below:

E. Leigh Mullikin, Esq.
Haynsworth, Baldwin Johnson & Greaves, P.A.
1201 Main Street
Suite 1230
Columbia, South Carolina 29201 

Dated this 4th day of October, 1990

NAPOLEON B. WILLIAMS, JR.



MEMORANDUM

To: Julius L. Chambers
Charles Stephen Ralston
Nina Pillard
Marc Goodheart
Deval Patrick
Thomas Henderson
Steve Shapiro
Laura Murray

The moot court in this case will be
Monday, January 7, 1991, at 2:30 p.m. in the 
large conference room. Jim Doyle, who will be 
arguing for petitioner, will be coming up from 
Louisiana.

Enclosed are copies of the brief for 
petitioner, brief for respondent, and en banc 
decision. There will probably be a reply 
brief for petition, which we will get to you 
as soon as possible.

From: Eric Schnapper

Date : January 2, 1991

Re : Edmondson v. Leesville Concrete

ES

Attach.

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IN THE
UNITED STATES COURT OF APPEALS

FOR THE FOURTH CIRCUIT

NO. 90-1797

CARRIE YOUNG- HENDERSON, 

vs.
Plantiff- Appellant

SPARTANBURG AREA MENTAL HEALTH CENTER, et al.,
Defendants- Appellees.

Appeal from the United States District Court 
For the District of South Carolina 

Greenville Division

CERTIFICATE OF SERVICE

I, Napoleon B. Williams, Jr., do hereby certify that I have 

this day served a copy of the within and foregoing Request for an 

Extension of Time in Which to File Appellant's Brief and Appendix 

upon counsel for the appellees by placing a copy of same in the 

United States mail, properly addressed and with the correct amount 

of postage affixed thereto, as well as faxed the same, and sending 

to said counsel at the address below:

E. Leigh Mullikin, Esq.
Haynsworth, Baldwin Johnson & Greaves, P.A.
1201 Main Street
Suite 1230
Columbia, South Carolina 29201 

Dated this 4th day of October, 1990

NAPOLEON B. WILLIAMS, JR.