RUSSEL ARTHUR, et al,
Defendants

Plaintiffs respectfully request that the Court grant leave to file plaintiffs' SECOND AMENDED COMPLAINT (accompanying this motion) instanter and out of time by two days. Pursuant to a stipulated motion, the Court granted plaintiffs leave to file a second amended complaint, to be filed with the Court by April 21. However, the filing has been delayed due to the difficulty of coordinating discussions between the three offices of plaintiffs' various counsel, two of whom are in Eugene, Oregon, but one of whom is in Chicago Illinois. See Declaration of Marianne Dugan. Allowing filing of this amended complaint will serve the interests of justice and efficiency of the

Court.

Respectfully submitted April 23, 1998.

(signed)

Brian Michaels, Esq
Counsel for Plaintiffs BRIAN MICHAELS and
BARRY ADAMS

(signed)

Reed Lee, Esq
Marianne Dugan, Esq, Local Counsel
Counsel for Plaintiffs ALEXIS BLACK CARLA
NEWBRE BRUCE (JOHN) JOHNSON and
SUSAN BERNSTEIN

BRIAN MICHAELS, ESQ;
259 East Fifth Avenue
Eugene, Oregon 97401
(541) 687-0578

Attorney for Plaintiffs Adams and Michaels

REED LEE
J.D. Obenberger & Associates
Attorneys & Counselors-at-Law
Three First National Plaza, Suite 3700
Chicago, IL 60602
(312) 558-6420
Attorney for Plaintiffs Black, Newbre,
Johnson, and Bernstein

MARIANNE DUGAN (OSB # 93256)
1216 Lincoln Street
Eugene, OR 97401
(541) 485-2471
Local Counsel for Plaintiffs Black, Newbre,
Johnson, and Bernstein