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

Filing 114

MOTION for Extension of Time to File Brief as to Issues Identified by the Court 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 7/8/2011. (Arnebeck, Clifford) Modified on 6/27/2011 to correct text & filing event (kk2)

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-745
PLAINTIFFS,
V.

JUDGE MARBLEY
MAGISTRATE JUDGE KEMP

OHIO SECRETARY OF STATE
JENNIFER BRUNNER, ET AL.

PLAINTIFFS’ MOTION FOR A TWO-WEEK EXTENSION WITHIN WHICH TO
FILE THEIR BRIEF AS TO ISSUES IDENTIFIED BY THE COURT
Plaintiffs move that they be granted an extension of two weeks in which to file their brief due
today in response to the issues identified by the Court.
Respectfully submitted,
/s/Clifford O. Arnebeck, Jr.
Clifford O. Arnebeck Jr. (0033391)
Trial Attorney for Plaintiffs
[e-mail]
1021 East Broad Street
Columbus, Ohio 43205
614-224-8771
Robert J. Fitrakis (0076796)
[e-mail]
1021 East Broad Street
Columbus, Ohio 43205
614-374-2380

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Henry W. Eckhart (0020202)
[e-mail]
Eckhart Law Offices
1200 Chambers Road, Suite 106
Columbus, OH 43212
614-461-0984
Counsel for Plaintiffs

MEMORADUM IN SUPPORT
Plaintiff’s counsel need to consult with their principal client in this matter, Rev. Jesse
Jackson of Rainbow PUSH Coalition, to determine whether he wants to proceed with this case
over the opposition of the offices of Ohio Attorney General Mike DeWine and Ohio Secretary of
State Jonathan Husted.
Rev. Jackson has been preoccupied with his annual conference in Chicago and a major
joint effort with the NAACP over the War on Drugs as The New Jim Crow pursuant to the views
of Attorney and Author Michelle Alexander.
Trial counsel for defendants has obtained the agreement of his client to this requested
extension.
Respectfully submitted,
/s/Clifford O. Arnebeck, Jr.
Clifford O. Arnebeck Jr. (0033391)
Trial Attorney for Plaintiffs
[e-mail]
1021 East Broad Street
Columbus, Ohio 43205
614-224-8771

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Robert J. Fitrakis (0076796)
[e-mail]
1021 East Broad Street
Columbus, Ohio 43205
614-374-2380
Henry W. Eckhart (0020202)
[e-mail]
Eckhart Law Offices
1200 Chambers Road, Suite 106
Columbus, OH 43212
614-461-0984
Counsel for Plaintiffs
CERTIFICATE OF SERVICE
A copy of the foregoing was served upon counsel through the court’s electronic filing
system, this 24th day of June 2011.
/s/ Clifford O. Arnebeck, Jr.
__________________________
Clifford O. Arnebeck, Jr.

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