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

Filing 22

MOTION for Extension of Time to File Response/Reply as to 21 MOTION to Dismiss Plaintiffs' Amended Complaint as Moot New date requested 2/5/2007. by Plaintiffs Ohio Voter Rights Alliance for Democracy, League of Young Voters/Columbus, Willis Brown, Paul Gregory, Miles Curtiss, Matthew Segal, Harvey Wasserman, King Lincoln Bronzeville Neighborhood Association. (Arnebeck, Clifford)

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

Doc. 22

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION : King Lincoln Bronzeville Neighborhood : : Association, et al., : : Plaintiffs, : : vs. : : J. Kenneth Blackwell, et al., : : Defendants. : Case No.: No. C2-06-745 Judge Algenon Marbley Magistrate Judge Kemp

PLAINTIFFS' MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT BLACKWELL'S MOTION TO DISMISS

Plaintiffs move for an extension of 30 days in which to respond to the Defendant Blackwell's Motion to Dismiss. By: /S/ Clifford O. Arnebeck, Jr. Clifford O. Arnebeck, Jr. (0033391) ([e-mail]) 341 South Third Street, Ste. 10 Columbus, Ohio 43215 Phone: [phone] Fax: [phone] Trial Attorney for Plaintiffs

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MEMORANDUM IN SUPPORT

Plaintiffs hereby request an extension of 30 days in which to respond to the Defendant Blackwell's motion to dismiss to permit them to reassess aspects of the complaint that may be affected by the change of administration in the office of the Secretary of State; and, in deference to scheduling conflicts of plaintiffs' counsel over and immediately following the holidays, including a jury trial in a wrongful death case.

Counsel for Defendant has consented to this request, which if granted would make the plaintiffs' response due by February 5, 2007.

Dated: Columbus, Ohio November 6, 2006

Respectfully Submitted,

By:

/S/Clifford O. Arnebeck, Jr. Clifford O. Arnebeck, Jr. (0033391) ([e-mail]) 341 South Third Street, Ste. 10 Columbus, Ohio 43215 Phone: [phone] Fax: [phone] Trial Attorney for Plaintiffs Henry W. Eckhart (0020202) ([e-mail]) 50 W. Broad St., #2117 Columbus, Ohio 43215 Phone: [phone] Fax: [phone] Co-Counsel

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OF COUNSEL: Robert J. Fitrakis (0076796) ([e-mail]) 341 S. Third St., Ste. 10 Columbus, Ohio 43215 Phone: [phone] Fax: [phone]

CERTIFICATE OF SERVICE This is to certify that the foregoing amended complaint was filed electronically on the 6th day of November 2006 in accordance with the Court's Electronic Filing Guidelines and upon other parties electronically or by US Mail. Notice of this filing will be sent to Christina Corl, Crabbe, Brown & James, Counsel for Defendant J. Kenneth Blackwell, Ohio Secretary of State, by operation of the Court's Electronic Filing System.

/S/ Clifford O. Arnebeck, Jr. Clifford O. Arnebeck, Jr.

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