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

Filing 115

Second MOTION for Extension of Time to File New date requested 7/12/2011. 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. (Arnebeck, Clifford)

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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-745 PLAINTIFFS, V. JUDGE MARBLEY MAGISTRATE JUDGE KEMP OHIO SECRETARY OF STATE JENNIFER BRUNNER, ET AL. PLAINTIFFS’ MOTION FOR A FURTHER EXTENSION WITHIN WHICH TO FILE THEIR BRIEF AS TO ISSUES IDENTIFIED BY THE COURT Plaintiffs move that they be granted an extension of an additional two business days 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 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 1 614-374-2380 Henry W. Eckhart (0020202) henryeckhart@aol.com Eckhart Law Offices 1200 Chambers Road, Suite 106 Columbus, OH 43212 614-461-0984 Counsel for Plaintiffs MEMORANDUM IN SUPPORT Trial counsel for the Defendant Ohio Secretary of State had agreed to provide plaintiffs with copies of the contracts between that office and GovTech and SmarTech. Today that commitment was reaffirmed. These contracts were discussed in the plaintiffs’ deposition of Michael Connell are relevant to both the jurisdictional and scope of ballot retention issues identified by the court for briefing by the parties. Trial counsel requests a further extension of two business days, until Tuesday, July 12, 2011, to file plaintiffs’ brief in this matter. Trial counsel for defendants has agreed to this requested extension. Respectfully submitted, /s/Clifford O. Arnebeck, Jr. Clifford O. Arnebeck Jr. (0033391) Trial Attorney for Plaintiffs clifford.arnebeck@gmail.com 1021 East Broad Street Columbus, Ohio 43205 614-224-8771 Robert J. Fitrakis (0076796) 2 robertfitrakis@gmail.com 1021 East Broad Street Columbus, Ohio 43205 614-374-2380 Henry W. Eckhart (0020202) henryeckhart@aol.com 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 8th day of July 2011. /s/ Clifford O. Arnebeck, Jr. __________________________ Clifford O. Arnebeck, Jr. 3

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