Attorneys for the Community for Creative Non-Violence filed a memorandum with the U.S. Court of Appeals yesterday charging that a plan by the federal government and the D.C. Coalition for the Homeless to house homeless District residents is a stopgap measure that lacks transportation services, requires shelter residents to work for their keep and makes no provision for housing women.

"Thirty percent of the shelter users must work -- without pay -- for four hours a day at the shelter and 20 percent must work eight hours a day," according to the memorandum.

Coalition officials disputed the CCNV statements yesterday, asserting that the group fully intends to develop housing for homeless women and will provide transportation for homeless residents to an old Navy Department building in Anacostia, which has been proposed by the coalition and the U.S. Department of Health and Human Services as a 600-bed, short-term shelter.

Lawrence Guyot, a coalition board member, said unpaid labor by shelter users would not be compulsory. He said the group's estimate that it will get $1.5 million worth of labor in the first year of operation is only a "mathematical projection of a theoretical."

"We don't have a commitment from one person," he said. "We are simply saying this is a projection of what we can expect as far as participation . . . . There is nothing sinister about this."

The memorandum filed yesterday is the latest development in the legal battle over the fate of the shelter at 425 Second St. NW, operated by CCNV. The federal Court of Appeals is considering an appeal of a lower court ruling that would let the federal government close the Second Street shelter so long as alternative housing for shelter residents is provided. The memorandum is CCNV's response to those alternative plans.

CCNV leader Mitch Snyder, in an interview yesterday, said the alternative plan offered last week by the coalition and HHS, which includes $3.7 million in federal funding, relies unrealistically on effective fund raising by the coalition and volunteer work by both residents of the shelter and nonresidents.

Guyot said that "we have no doubt" the fund-raising efforts, expected to be led by Susan Baker, wife of U.S. Treasury Secretary James A. Baker, will be adequate.