UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 
FERDINAND J. MACK, Jr. ) 
) 
Plaintiff, ) 
) 
v. ) 
) 
JOSEPH A. CALIFANO , Jr., ) 
et al. , ) 
) 
Defendants. ) 
) 
Civil Action No. 77-916 
FILED 
JAN 2 01978 
MEMORANDUM IN OPPOSITION TO PLAINTIFF ' S JAMES F. DAV^Y, Clerk 
REQUEST TO DEFER FOR 30 DAYS 
Plaintiff has moved the Court for a 30-day extension 
of time to submit additional information. In effect, plaintiff 
asks the Court to enter a 30- day preliminary injunction without 
having to meet any of the requirements for a preliminary injunc- 
tion. For the reasons discussed below, plaintiff's motion should 
be denied. 
First, plaintiff in essence asks the Court to 
enter a preliminary injunction for 30 days. Such an injunction 
must be accompanied by the normal proof of probable success 
on the merits , probability of irreparable harm, and general 
public interest. As indicated in our Opposition to Plaintiff's 
Original Motion for a Preliminary Injunction (hereinafter "Def. 
Opp."), filed December 30, 1977, plaintiff has made no such 
showing. Nothing in plaintiff's new papers indicate any addi- 
tional reasons as to why plaintiff should be given preliminary 
injunctive relief. Indeed, we know of no authority for the 
Court to preliminarily enjoin for 30 days without plaintiff 
[Appendix C — 175] 
