King Lincoln Bronzeville Neighborhood Association et al v. J. Kenneth Blackwell et al

Filing 105

First MOTION for Extension of Time to File Response/Reply as to 102 MOTION for Reconsideration re 101 Opinion and Order and Request for Emergency Hearing by Plaintiffs Willis Brown, Miles Curtiss, Paul Gregory, King Lincoln Bronzeville Neighborhood Association, League of Young Voters/Columbus, Ohio Voter Rights Alliance for Democracy, Matthew Segal & Harvey Wasserman. New date requested 1/3/2011. (Arnebeck, Clifford) Modified on 12/29/2010 to correct doc link to mtn (kk2)

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IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO, EASTERN DIVISION King Lincoln Brownsville Neighborhood Association, et al. Case No. 2:06-CV-00745 Plaintiffs, v. Judge Marbley Magistrate Judge Kemp Ohio Secretary of State Jennifer Brunner, et al. Defendants. MOTION TO EXTEND TIME FOR FILING REPLY BRIEFS Plaintiffs move for a one week extension of time in which to file their replies to the memoranda contra to their motion for reconsideration of the Magistrate Judge’s Opinion and Order. Counsel for defendants and non-party Ohio Chamber of Commerce have agreed to this request. Respectfully submitted, /s/Clifford O. Arnebeck, Jr. Clifford O. Arnebeck Jr. (0033391) Trial Attorney for Plaintiffs arnebeck@aol.com 1021 East Broad Street Columbus, Ohio 43205 614-224-8771 Robert J. Fitrakis (0076796) truth@freepress.org 1021 East Broad Street Columbus, Ohio 43205 614-224-8771 Henry W. Eckhart (0020202) 1 henryeckhart@aol.com 50 West Broad Street, Suite 2117 Columbus, Ohio 43215 614-461-0984 Counsel for Plaintiffs MEMORANDUM IN SUPPORT Because of the broad scale response of both the Chamber and Defendants as well as Plaintiffs’ trial counsel’s holiday travel, plaintiffs have requested and received agreement of opposing counsel to a one week extension in time to reply. With such extension plaintiffs’ replies will be due by January 3, 2011. Respectfully submitted, /s/Clifford O. Arnebeck, Jr. Clifford O. Arnebeck Jr. (0033391) Trial Attorney for Plaintiffs arnebeck@aol.com 1021 East Broad Street Columbus, Ohio 43205 614-224-8771 Robert J. Fitrakis (0076796) truth@freepress.org 1021 East Broad Street Columbus, Ohio 43205 614-374-2380 Henry W. Eckhart (0020202) henryeckhart@aol.com 50 West Broad Street, Suite 2117 Columbus, Ohio 43215 614-461-0984 Counsel for Plaintiffs 2 CERTIFICATE OF SERVICE A copy of the foregoing was served upon counsel for the parties and respondent through the court’s electronic filing system, this 28th day of December 2010. /s/ Clifford O. Arnebeck, Jr. ___________________________ Clifford O. Arnebeck, Jr. 3

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