Skinner et al v. New York Times Company

Filing 69

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Skinner et al v. New York Times Company Doc. 69 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION M. DAVID REID, Individually and As Administrator of the Estate of Mary Ann Reid, Deceased, ) ) ) ) ) Plaintiff, ) ) v. ) ) UNITED STATES POSTAL SERVICE, ) et al., ) ) Defendants. ) CASE NO. 3:07CV0453 JUDGE WALTER H. RICE MAG. JUDGE SHARON L. OVINGTON MOTION FOR CONTINUANCE OF TRIAL Defendant, United States of America, respectfully moves the Court for a continuance of the trial in this action which is currently scheduled for June 15, 2009. As the basis for this, the United States represents as follows: (1) factual discovery is still on-going and there are a number of discovery disputes which must be resolved; (2) no expert discovery has yet taken place; and (3) there currently is pending a Motion for Partial Summary Judgment, to which the other parties have not yet responded, which may be dispositive of a central issue in this case. Accordingly, the case is not ready for trial nor is it anticipated that it can be ready by the scheduled trial date. WHEREFORE, the United States of America respectfully moves for a continuance of the scheduled trial date. Respectfully submitted, WILLIAM J. EDWARDS United States Attorney s/William J. Kopp WILLIAM J. KOPP (#0024018) JAMES R. BENNETT II (#0071663) Assistant United States Attorney 400 United States Courthouse 801 West Superior Avenue Cleveland, Ohio 44113 (216) 622-3696;(216) 622-3988 (216) 522-4982 - Facsimile CERTIFICATE OF SERVICE I hereby certify that on this 4th day of March, 2009, a copy of the foregoing Motion for Continuance of Trial was filed electronically. Notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. s/William J. Kopp WILLIAM J. KOPP JAMES R. BENNETT II Assistant U. S. Attorneys 2

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