IN THE UNITED STATES COURT OF APPEALS
 FOR THE SEVENTH CIRCUIT
 EASTERN DIVISION

UNITED STATES OF AMERICA,       )
                                                )
                        Plaintiff.              )       CASE NO. 94 24 83
                                                )
                v.                              )       JUDGE LEINENWEBER
                                                )
 MICHAEL WILLIAMS,                       )
                                                )
                        Defendant.              )

MOTION FOR AN EXTENSION OF TIME
 PRO SE APPELLANT

TO:     Mr. Thomas F. Strubbe                   Carol A. Davilo
        Clerk of the U.S. Court of Appeals              Assistant United States Attorney
        219 S. Dearborn, 20th Fl.                       219 S. Dearborn, 20th Fl.
        Chicago, IL   60604                             Chicago, IL   60604

        Juleann Hornyak                         SA Richard Loyd
        Clerk of the Supreme Court                      FBI - Room 905
        Supreme Court Building                  219 S. Dearborn
        Springfield, IL   62706                 Chicago, IL   60604

        William J. Stevens                              A.R.D.C.

        135 S. La Salle St.                             One Prudential Plaza

        Suite 1407                                      130 E. Randolph Drive

        Chicago, IL   60603                             Chicago, IL 60601-6219

        Boutros Boutros-Ghali                   J. Moller, Chief of Branch
        Secretary General                               Centre for Human Rights
        United Nations                          United Nations
        Room S-3800A                            Palais des Nations

        New York, NY   10014                    8 - 14 Avenue de la Paix
                                                        1211 Geneva 10

        Robert G. Clarke                                Amnesty International
        7035 N. Clark St.                               Monbijoustrasse 26/Postfach
        Chicago, IL   60626                             CH-3011 Bern
                                                        Switzerland


        United States upreme Court              Dr. A. Zumstein Schmid, M.D

        1 First St., N.E.                               Lerchenweg 18
        Washington, D.C.   20543                        CH-3110 Muensingen
                                                        Switzerland

 I, Michael Williams, declare that I am the Defendant in the above-entitled proceeding. I
 am not an attoney, do not have the funds necessary to retain one, have not been

appointed one despite my many persistent requests, and am thus being forced to prepare
 this motion myself, even though I am not qualified to do so.

1.      A communication dated 16. August 1995 and sent via sea which Defendant- Appellant has received from the Court ordered that "The brief and required short appendix
 of the appellant are due by 9/25/95".

An extension of time is essential in the interests of justice and not unreasonable for the
 following reasons:

a.)      Defendant is unqualified to prepare an appellate brief, and requires appointment
 of counsel to prepare said brief for him. The extension Defendant is requesting takes into
 consideration the fact that counsel must first be appointed to this case, become familiar
 with it, and perform a great deal of research prior to preparing a brief.

b.)     Defendant is not a legal scholar. This is a very serious case, which requires the
 dedicated representation of a highly-qualified, experienced, independent attorney.
 Defendant does not have the slightest idea how to prepare an appellate brief. Defendant
 has no idea what a "required short appendix" is. Defendant has no legal training, hence
 his persistent requests for legal counsel to be appointed, and his diligent efforts to comply
 with the Court's orders to the best of his ability from the distant foreign country to which
 he has lived in exile for nearly half a decade.

c.)     Defendant does not have access to any U.S. legal libraries, and wouldn't know
 how to use them, even if he did. Defendant resides in exile in a distant foreign country
 where the local language is an unwritten German dialect.

d.)     Defendant has no guides to indicate what form legal documents to the Court must
 be in.

e.)     Defendant has no finances necessary for research, investigation, computer on-line
 legal services, international long-distance telephone calls and faxes, law libraries or any
 other resources essential for properly and effectively defending his appeal, and wouldn't
 know how to use them, even if he did.

f.)     Defendant is in failing health, which his doctor has confirmed to the Court is
 deteriorating rapidly as a direct result of his being forced to defend this appeal without
 proper legal assistance. Attempting to defend this appeal without proper qualifications or
 resources is endangering Defendant's life. Even if Defendant were a properly-qualified
 attorney, which he is not, and had the necessary resources, which he does not, he is not

- 2 -
 in the physical condition to represent himself. Defendant's family physician, Dr. A.
 Zumstein Schmid, M.D., wrote the Court on 13. March 1995 regarding Defendant's deteriorating physical condition, and how his being forced to defend this appeal without
 proper legal assistance is endangering his life. Since the writing of said letter, and the
 extreme and constant pressure put on Defendant to prepare an appellate brief, his health
 has begun to deteriorate even more rapidly, and he may be hospitalised soon.

g.)     Defendant has never been properly represented by legal counsel on this case since
 the time of his arrest on 18. March 1988. Defendant was previously represented by
 attorney William J. Stevens, appointed by Hon. Harry Leinenweber. Attorney Stevens
 never properly represented Defendant, refused to file essential motions or prepare a
 proper defence, used sinister methods to coerce him to plea guilty, has refused to
 represent him since 13. July 1992, leaving him without counsel at a time when he most
 urgently required it. Defendant's serious formal complaint against said attorney with the
 Attorney Registration and Disciplinary Commission of the Supreme Court Of Illinois
 (Case No. 93-CI-971), which includes numerous charges of both ethical and criminal
 misconduct, is pending.

h.)      There would be a lack of prejudice on either side if a continuance is granted,
 considering how many years this case has gone on, already - entirely because of the U.S.
 Attorney's outrageous negligence.

i.)     The U.S. Attorney's Office did not file this motion until several years after the
 unlawful seizure of Defendant's assets occurred, and only then, after serious enquiries
 from U.S. Senator Dianne Feinstein to the F.B.I. into Defendant's case motivated the
 F.B.I. to apply pressure on the U.S. Attorney's Office to file this motion, which should
 have been filed in 1988, if they intended to "legalise" this illegal seizure.

j.)     Defendant's Freedom of Information Act request to the F.B.I. dated 22. July

1994 and his follow-up letter to their director, Louis Freeh, dated 18. August 1994, have
 been ignored. This information is crucial to Defendant's having a fair hearing. Defendant
 requires an extension of time in order to await this essential material.

k.)     Defendant's former counsel, Robert G. Clarke, and this Court, have denied Defendant's numerous requests to provide him with a copy of the government's answer
 to his 41 e motion. It is impossible to defend an appeal when one does not even know

- 3 -
 what his adversary has written. Defendant requires an extension of time in order to await
 this essential material.

l.)     Defendant's former counsels, William J. Stevens, Robert G. Clarke, and H. Stuart Cunningham, Clerk of the United States District Court and Thomas F. Strubbe,
 Clerk of the U.S. Court of Appeals have denied Defendant's numerous requests to

provide him not only with a copy of the government's answer to his 41 e motion, but to
 the court record and essential transcripts, in particular the transcripts from the District
 Court hearing, where Defendant's 41 e motion was wrongfully denied without argument.
 Defendant requires an extension of time in order to await this essential material.

2.      A communication dated 8. August 1995, amended 22. August 1995 and sent via sea which Defendant-Appellant has received from the Court indicated that Defendant's
 Motion for Appointment of Counsel had been denied. Defendant intends to file a Motion
 to Reconsider Motion for Appointment of Counsel.

3.      Defendant requires a Memorandum of Facts and Law in order to properly prepare
 an effective appellate brief, and, as such, has filed his Petition for Memorandum of Facts
 and Law with this court, and is awaiting disposition of said Petition. Defendant requires
 an extension of time in order to await said disposition and receive this essential material,
 without which the preparation of an appellate brief is impossible.

4.      Due to the Court's consistently denying Defendant's persistent requests for appointment of counsel, Defendant is seeking to obtain Pro Bono counsel, and, as such,
 is presently negotiating with several attorneys, in particular, Robert S. Meloni [405 Park
 Ave., New York, NY   10022, Tel.: (212)935-0900]. Mr. Meloni requires a copy of the
 court record, the government's response to Defendant's 41 e motion, and a transcript of
 the hearing on said motion in Hon. Harry Leinenweber's court in order to make a

decision on whether or not to accept Defendant's case on a Pro Bono basis. Defendant
 requires an extension of time in order to await this essential material in the hopes of, at
 last, obtaining competent counsel of his choice, as guaranteed under the United States Constitution.

5.      Although Defendant is hopeful that this Court will, in observe of his constitutional
 right to appointment of competent counsel, appoint him counsel, or that, as an alternative,
 Defendant is successful in obtaining Pro Bono counsel, his supporters are prepared to
 form a Legal Defence Committee for the purposes of retaining competent counsel, if

- 4 -
 necessary. In order for such a determination to be made, Defendant must first be provided
 with the essential copies of the court record, the government's response to Defendant's
 41 e motion, and a transcript of the hearing on said motion in Hon. Harry Leinenweber's
 court, in order to determine if it will be possible for Defendant to obtain Pro Bono
 counsel, or if the launching of a Legal Defence Committee will be necessitated, in the
 event neither court-appointed nor Pro Bono counsel is made available to him. Defendant
 requires an extension of time in order to await this essential material.

6.      All of Defendant's constitutional rights have been denied up to now, including his
 constitutional right to counsel in this appeal. Defendant desperately requires an extension
 of time for the above reasons, amongst others, in the interests of justice, and in
 observance of his Constitutional rights.

WHEREAS Defendant requests that an extension of time be granted.


                                                Respectfully submitted,





                                                MICHAEL WILLIAMS, in Pro Se
                                                Postfach 20
                                                CH-3112 Allmendingen bei Bern
                                                Switzerland



- 5 -
 AFFIDAVIT OF MAILING

CANTON OF BERNE                 )
                                                )
 COUNTRY OF SWITZERLAND  )

MICHAEL WILLIAMS swears that on the 11th day of August, 1995, he placed
 a copy of MOTION FOR EXTENSION OF TIME - PRO SE APPELLANT in envelopes addressed to the following named individuals and caused the envelopes to be deposited in
 the Swiss mail depository located at the PTT Post Office in Muensingen, Switzerland on
 said date at or before the hour of 5:00 p.m.

        Mr. Thomas F. Strubbe                   Carol A. Davilo
        Clerk of the U.S. Court of Appeal               Assistant United States Attorney
        219 S. Dearborn, 20th Fl.                       219 S. Dearborn, 20th Fl.
        Chicago, IL   60604                             Chicago, IL   60604

        Juleann Hornyak                         SA Richard Loyd
        Clerk of the Supreme Court                      FBI - Room 905
        Supreme Court Building                  219 S. Dearborn
        Springfield, IL   62706                 Chicago, IL   60604

        William J. Stevens                              A.R.D.C.

        135 S. La Salle St.                             One Prudential Plaza

        Suite 1407                                      130 E. Randolph Drive

        Chicago, IL   60603                             Chicago, IL 60601-6219

        Boutros Boutros-Ghali                   J. Moller, Chief of Branch
        Secretary General                               Centre for Human Rights
        United Nations                          United Nations
        Room S-3800A                            Palais des Nations

        New York, NY   10014                    8 - 14 Avenue de la Paix
                                                        1211 Geneva 10

        Robert G. Clarke                                Amnesty International
        7035 N. Clark St.                               Monbijoustrasse 26/Postfach
        Chicago, IL   60626                             CH-3011 Bern
                                                        Switzerland


        United States Supreme Court             Dr. A. Zumstein Schmid, M.D

        1 First St., N.E.                               Lerchenweg 18
        Washington, D.C.   20543                        CH-3110 Mueingen
                                                        Switzerland

                                                Respectfully submitted,



                                                                         

                                                MICHAEL WILLIAMS
                                                Postfach 20
                                                CH-3112 Allmendingen bei Bern
                                                Switzerland