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)
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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