On June 01, 2011 a
Order
was filed
for OTHER CIVIL
in the District Court of Franklin County.
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Franklin County Ohio Clerk of Courts of the Common Pleas- 2012 Feb 13 4:47 PM-11CV006773
OA228 - L42
IN THE COURT OF COMMON PLEAS
FRANKLIN COUNTY, OHIO.
BRENDA HARRINGTON,
Plaintiff, Case No. 11CV-06-6773
v. : JUDGE BEATTY
CITY OF COLUMBUS, et al.,
Defendants.
PLAINTIFF BRENDA HARRINGTON’S MOTION FOR
EXTENSION OF TIME TO RESPOND TO DEFENDANTS’
MOTION FOR JUDGMENT ON THE PLEADINGS
Now comes the Plaintiff, Brenda Harrington, by and through her counsel,
Byron L. Potts, pursuant to Loc. R. 13.01, and moves this court to grant her motion
for extension of time to respond to Defendants’ Motion for Judgment on the
Pleadings. The Plaintiffs reasons for the aforementioned motion are more fully set
forth in the memorandum below.
Respectfully submitted,
/s/Byron L. Potts,
Byron L. Potts (0040246)
Attorney for Plaintiff Brenda Harrington
415 East Broad Street, Suite 112
Columbus, Ohio 43215
(614) 228-2154, Telephone
(614) 228-2155, Facsimile
byronpotts@ msn.comFranklin County Ohio Clerk of Courts of the Common Pleas- 2012 Feb 13 4:47 PM-11CV006773
0A228 - L43
MEMORANDUM IN SUPPORT
On January 23, 2012, the Defendants filed a motion for judgment on the pleadings.
The certificate of service says that it was served on January 24, 2012 to counsel for Plaintiff.
However, said pleading was not received by Counsel for Plaintiff electronically until
February 13, 2012 and there was never a hardcopy mailed to Counsel. The problem may be
due to the fact that the new electronic filing system for the court is new and there are still
some bugs to be worked out regarding the receipt of email notice of filed pleadings.
WHEREFORE, Plaintiff, Brenda Harrington, respectfully requests that this court
grant her a thirty (30) day extension of time so that counsel may prepare an appropriate
answer.
Respectfully submitted,
/s/Byron L. Potts
Byron L. Potts (0040246)
Attorney for Plaintiff Brenda Harrington
415 East Broad Street, Suite 112
Columbus, Ohio 43215
(614) 228-2154, Telephone
(614) 228-2155, Facsimile
byronpotts@msn.comFranklin County Ohio Clerk of Courts of the Common Pleas- 2012 Feb 13 4:47 PM-11CV006773
OA228 - L44
CERTIFICATE OF SERVICE
This is to certify that a true copy of the foregoing Plaintiff’s Motion for
Extension of Time to Respond to Defendants’ Motion for Judgment on the Pleadings
was sent by electronic mail to Susan E. Thompson, Esq., Attorney for Defendants, at
90 West Broad Street, Room 200, Columbus, Ohio 43215, on this 2B day of
February, 2012.
Respectfully Submitted,
Byron L. Potts & Co., LPA
/s/ Byron L, Potts,
Byron L. Potts (0040246)
Attorney for Plaintiff Brenda Harrington
415 East Broad Street, Suite 112
Columbus, Ohio 43215
614/228-2154
Document Filed Date
February 13, 2012
Case Filing Date
June 01, 2011
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Franklin County Ohio Clerk of Courts of the Common Pleas- 2012 Feb 13 4:47 PM-11CV006773 OA228 - L42 IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO. BRENDA HARRINGTON, Plaintiff, Case No. 11CV-06-6773 v. : JUDGE BEATTY CITY OF COLUMBUS, et al., Defendants. PLAINTIFF BRENDA HARRINGTON’S MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANTS’ MOTION FOR JUDGMENT ON THE PLEADINGS Now comes the Plaintiff, Brenda Harrington, by and through her counsel, Byron L. Potts, pursuant to Loc. R. 13.01, and moves this court to grant her motion for extension of time to respond to Defendants’ Motion for Judgment on the Pleadings. The Plaintiffs reasons for the aforementioned motion are more fully set forth in the memorandum below. Respectfully submitted, /s/Byron L. Potts, Byron L. Potts (0040246) Attorney for Plaintiff Brenda Harrington 415 East Broad Street, Suite 112 Columbus, Ohio 43215 (614) 228-2154, Telephone (614) 228-2155, Facsimile byronpotts@ msn.comFranklin County Ohio Clerk of Courts of the Common Pleas- 2012 Feb 13 4:47 PM-11CV006773 0A228 - L43 MEMORANDUM IN SUPPORT On January 23, 2012, the Defendants filed a motion for judgment on the pleadings. The certificate of service says that it was served on January 24, 2012 to counsel for Plaintiff. However, said pleading was not received by Counsel for Plaintiff electronically until February 13, 2012 and there was never a hardcopy mailed to Counsel. The problem may be due to the fact that the new electronic filing system for the court is new and there are still some bugs to be worked out regarding the receipt of email notice of filed pleadings. WHEREFORE, Plaintiff, Brenda Harrington, respectfully requests that this court grant her a thirty (30) day extension of time so that counsel may prepare an appropriate answer. Respectfully submitted, /s/Byron L. Potts Byron L. Potts (0040246) Attorney for Plaintiff Brenda Harrington 415 East Broad Street, Suite 112 Columbus, Ohio 43215 (614) 228-2154, Telephone (614) 228-2155, Facsimile byronpotts@msn.comFranklin County Ohio Clerk of Courts of the Common Pleas- 2012 Feb 13 4:47 PM-11CV006773 OA228 - L44 CERTIFICATE OF SERVICE This is to certify that a true copy of the foregoing Plaintiff’s Motion for Extension of Time to Respond to Defendants’ Motion for Judgment on the Pleadings was sent by electronic mail to Susan E. Thompson, Esq., Attorney for Defendants, at 90 West Broad Street, Room 200, Columbus, Ohio 43215, on this 2B day of February, 2012. Respectfully Submitted, Byron L. Potts & Co., LPA /s/ Byron L, Potts, Byron L. Potts (0040246) Attorney for Plaintiff Brenda Harrington 415 East Broad Street, Suite 112 Columbus, Ohio 43215 614/228-2154