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

Filing 63

MOTION for Leave to File Reply Memorandum 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. 63

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 FOR LEAVE TO REPLY TO DEFENDANT'S OPPOSITION TO RELIEF FROM STAY

Plaintiffs move for leave to file, on September 17, 2008, their reply to defendant's opposition to plaintiffs' motion for relief from the stay of this matter. Respectfully submitted, /s/ Clifford O. Arnebeck, Jr. Clifford O. Arnebeck Jr. (0033391) Trial Attorney [e-mail] Robert J. Fitrakis (0076796) [e-mail] 1021 East Broad Street 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

Due to the disruption of the availability of plaintiffs' counsel's office, because of the power outage in Columbus from late Sunday, September 14 afternoon through the afternoon of today, September 17, and conflicting demands on the time of plaintiff's expert Stephen Spoonamore who was in Atlanta, Georgia all this week, plaintiffs' counsel was unable to complete filing of plaintiffs' reply in this matter on September 16th. Plaintiff's counsel requests leave to file plaintiffs' reply, with supporting attachments, one day late, this 17th day of September 2008.

Defendant Secretary of State does not object to the granting of this request for leave to file late, in these circumstances.

Wherefore, plaintiffs submit that their unopposed request for additional time for their reply is in the interest of justice and should be granted. 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 2

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 on this 17th day of September 2008. /s/ Clifford O. Arnebeck, Jr.

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