216 Jamaica Avenue v. S & R Playhouse Realty Co.

Filing 62

Unopposed Motion for a Rescheduled Status Conference filed by Plaintiff 216 Jamaica Avenue. (Cooper, Charles)

216 Jamaica Avenue v. S & R Playhouse Realty Co.

Doc. 62

Case: 1:06-cv-01288-CAB Doc #: 62 Filed: 03/03/09 1 of 3. PageID #: 1625

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO __________________________________________ ) 216 JAMAICA AVENUE, LLC, ) Civil Action No. 06-1288 ) Plaintiff, ) (Judge Boyko) ) v. ) ) S & R PLAYHOUSE REALTY CO., ) ) Defendant. ) __________________________________________) PLAINTIFF'S UNOPPOSED MOTION TO RESCHEDULE STATUS CONFERENCE On March 2, 2009, the Court set a Status/Case Management Conference for March 24, 2009, at 10:00am. David Thompson is the lead attorney for the Plaintiff, 216 Jamaica Avenue, LLC ("Jamaica"), and will be representing Jamaica at the Status/Case Management Conference. Mr. Thompson has longstanding plans to be on vacation with his family during the week of March 24. Accordingly, Jamaica respectfully requests that the Court reschedule the conference. Stephen Williger, lead counsel for the Defendant, S&R Playhouse Realty Co. ("S&R"), has represented to Jamaica that S&R does not oppose this motion. If convenient for the Court, both Mr. Williger and Mr. Thompson would be available the morning of April 2, 2009. If that date is inconvenient for the Court, the parties would welcome the opportunity to submit other dates. Jamaica and its counsel greatly appreciate the Court's consideration of its request.

Dockets.Justia.com

Case: 1:06-cv-01288-CAB Doc #: 62 Filed: 03/03/09 2 of 3. PageID #: 1626

March 3, 2009

Respectfully Submitted, /s/ Charles J. Cooper _____________________________ Charles J. Cooper [e-mail] David H. Thompson [e-mail] David Lehn [e-mail] COOPER & KIRK, PLLC 1523 New Hampshire Ave. NW Washington, DC 20036 [phone] [phone] (fax) Attorneys for Plaintiff

James B. Niehaus (0020128) [e-mail] Christopher G. Keim (0067117) [e-mail] FRANTZ WARD LLP 2500 Key Center 127 Public Square Cleveland, Ohio 44114-1230 216-515-1660 216-515-1650 (fax)

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Case: 1:06-cv-01288-CAB Doc #: 62 Filed: 03/03/09 3 of 3. PageID #: 1627

CERTIFICATE OF SERVICE I hereby certify on March 3, 2009, a copy of the foregoing was filed electronically. Notice of this filing will be sent by operation of the Court's electronic filing system to all parties indicated on the electronic filing receipt. All other parties will be served by regular U.S. mail. Parties may access this through the Court's system.

/s/ David Lehn _____________________________ David Lehn COOPER & KIRK, PLLC 1523 New Hampshire Ave. NW Washington, DC 20036 [phone] [phone] (fax) [e-mail]

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