Now comes the Board of Trustees of the Columbus Metropolitan Library (the "Metropolitan Library"), Larry Black, and Vonzell Johnson and move this Court pursuant to Rule 6(B) of the Ohio Rules of Civil Procedure for an extension of time in which to Answer or otherwise respond to the Complaint, from May 10, 2001 to May 24, 2001. A memorandum in Support of this Motion is attached.

The instant case provides good cause justifying extension of the time limit for filing an answer or motion to dismiss provided by Civ. R. 12(a). Plaintiff alleges that Defendants were involved in a series of actions (both formal and informal) which deprived him of the ability to use the Metropolitan Library facilities based on his refusal to wear shoes. Although Defendants deny the legal interpretation of these facts espoused by Plaintiff, they have not yet completed, through counsel, an investigation sufficient to confirm or deny many of the specific factual allegations contained in the Complaint.

Defense counsel was retained to defend this action and first received the complaint on May 8, 2001, only two days before the filing date provided by Civ. R. 12(a) would elapse. Counsel has thus been unable to fully develop, in conjunction with the Defendants, the factual information necessary to frame a truthful Answer or to determine whether a different response is appropriate. As a result, the Defendants request that the Court extend the time permitted to respond to May 24, 2001.

The undersigned hereby certifies that a copy of the foregoing Defendant's Motion for Extension of Time to Answer or Otherwise Respond was served, by regular U.S. mail, postage prepaid, upon Robert A. Neinast, Plaintiff, 8617 Ashford Lane, Pickerington, Ohio 43147 this 10th day of May, 2001.