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

Filing 51

MOTION for Extension of Time to File Response/Reply New date requested 9/5/2008. 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. 51

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO, EASTERN DIVISION KING LINCOLN BRONZEVILLE NEIGHBORHOOD ASSOCIATION, ET AL., CASE NO. 2:06-CV-745 PLAINTIFFS, JUDGE MARBLEY VS. MAGISTRATE JUDGE KEMP JENNIFER BRUNNER, ET AL., DEFENDANTS.

PLAINTIFFS' MOTION TO EXTEND TIME TO REPLY TO MOVING INTERVENORS' RESPONSE TO PLAINTIFFS' MOTION TO STRIKE

Plaintiffs move to extend by three days the time to reply to moving intervenors' response to plaintiffs' motion to strike the pending motion for leave to intervene. Respectfully submitted, /s/ Clifford O. Arnebeck, Jr. Clifford O. Arnebeck Jr. (0033391) Trial Attorney [e-mail] Robert J. Fitrakis (0076796) [e-mail] 1000 East Main Street, Suite 102 Columbus, Ohio 43215 614-224-8771 Henry W. Eckhart (0020202) [e-mail] 50 West Broad Street, Suite 2117 Columbus, Ohio 43215 614-461-0984 Counsel for Plaintiffs

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MEMORANDUM IN SUPPORT OF MOTION

Plaintiffs request an extension of three days, to September 5, 2008, to reply to moving intervenors' response to plaintiffs' motion to strike their motion for leave to intervene.

Plaintiffs' trial attorney, because of his competing work load, including preparation of a response to the Defendant's opposition to Plaintiffs' motion for relief from the stay in this case, and a long scheduled out-of-state family summer vacation through the end of August, requires several more days to complete a response. Respectfully submitted, /s/Clifford O. Arnebeck, Jr. Clifford O. Arnebeck Jr. (0033391) Trial Attorney [e-mail] Robert J. Fitrakis (0076796) [e-mail] 1000 East Main Street, Suite 102 Columbus, Ohio 43215 614-224-8771 Henry W. Eckhart (0020202) [e-mail] 50 West Broad Street, Suite 2117 Columbus, Ohio 43215 614-461-0984 Counsel for Plaintiffs

CERTIFICATE OF SERVICE This is to certify a copy of the foregoing was served upon counsel of record by means of the Court's electronic filing system and upon the pro se moving intervenors by ordinary mail on this 2nd day of September 2008 . /s/ Clifford O. Arnebeck, Jr. 2