Motion for an Extension of Time in Which to File Brief and Appendix
Public Court Documents
March 10, 1977
Cite this item
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Case Files, Garner Hardbacks. Motion for an Extension of Time in Which to File Brief and Appendix, 1977. f6f223b7-26a8-f011-bbd3-000d3a53d084. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/b71aaded-6648-4189-a70a-1fcceb35dddc/motion-for-an-extension-of-time-in-which-to-file-brief-and-appendix. Accessed February 12, 2026.
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IN THE
UNITED STATES COURT OF APPEALS
FOR THE SIXTH CIRCUIT
NO. 77-1089
CLEAMTEE GARNER, ETC.,
Plaintiff-Appellant,
V.
MEMPHIS POLICE DEPARTMENT,
et al.,
Defendants-Appellees,
Plaintiff-appellant Cleamtee Gamer, respectfully moves
this Court for an Order extending the time for filing his Brief
and Appendix in this case for a period of 30 days, to and
including April 25, 1977. In support of this Motion, plaintiff-
appellant would show the following:
1. The present due date for the Brief and Appendix
is March 26, 1977.
2. The attorney who was to have prepared the Brief and
Appendix is Drew S. Days, III, Esq., who was also involved in the
trial of the case below.
3. Mr. Days has been appointed to the Department of Justice
as Assistant Attorney General for Civil Rights, and was sworn in
on March 10, 1977. Because of the assumption of his new duties he
will be unable to participate further in this litigation.
4. Thus, it is necessary for new counsel to familiarize
themselves with the record in this case so as adequately to
brief the issues involved. it will be impossible for them to do
so by the present due date.
5. A thirty-day extension of time will not prejudice
the rights of the Defendants-Appellants.
WHEREFORE, for the foregoing reasons, an extension of
time to and including April 25, 1977 is requested.
Respectfully submitted.
JACK GREENBERG
CHARLES STEPHEN RALSTON
10 Columbus Circle
Suite 2030
New York, New York 10019
WALTER L. BAILEY, JR.
D'ARMY BAILEY
Suite 901, Tenoke Building
161 Jefferson Avenue
Memphis, Tennessee 38103
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■■■ h
MAURICE FRANKLIN
Suite 1414 Parkway Towers
404 James Robertson Parkway
Nashville, Tennessee 37219
Attorneys for Plaintiffs-
Appellant^ ^
/
By: f ■■ / ' c X T
CERTIFICATE OF SERVICE
/ I .
I hereby certify that a copy of the foregoing Motion
v;. ' - '■ ' -
was seirved on counsel for Defendants-Appellants by depositing
same in the United States mail, first class, postage prepaid,
addressed to Henry L- Klein, Esq., 3500 - 100 N. Main Building,
Memphis, Tennessee, 38103.
Done this ]__ day of March, 1977.
, / f
Counsel for Plaintiff-Appellant
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