Opinion
3 JD 2016
12-01-2016
SECOND MOTION TO EXTEND THE TIME TO FILE PRE-TRIAL MEMORANDUM
The Respondent, former Judge David Tidd, by his counsel, Samuel C Stretton, Esquire, respectfully requests this Honorable Court extend the time to file a Pre-Trial Memorandum for the following reasons:
1. The Respondent's Pre-Trial Memorandum was initially due on or before November 15, 2016.
2. Mr. Stretton had withdrawn as counsel due to some disagreements with the Respondent, but those matters were resolved. Mr. Stretton re-entered his appearance and filed the first Motion for an Extension of Two (2) Weeks to File the Pre-Trial Memorandum, which this Honorable Court granted.
3. The Respondent's Pre-Trial Memorandum is now due on or before December 5, 2016.
4. Mr. Stretton is respectfully requesting an extension of eight (8) days beyond the December 5, 2016 date for the following reasons:
a.) Present counsel has been on trial almost constantly since he was re-retained by Mr. Tidd.
b.) Present counsel has election trials this week and two major Supreme Court arguments and two other trials next week.
c.) Present counsel is working with counsel for the Judicial Conduct Board, Elizabeth Flaherty, Esquire, to work out detailed stipulations.
d.) Ms. Flaherty has no objection to this request for an extension of eight (8) days.
e.) Although he is asking for an extension of time to file the Pre-Trial Memorandum, present counsel respectfully requests this Honorable Court maintain the pre-trial conference date of December 14, 2016.
WHEREFORE, the Respondent, David Tidd, by his counsel, Samuel C. Stretton, Esquire, respectfully requests this Honorable Court grant him an extension of eight (8) days to file the Pre-Trial Memorandum, which would make the Pre-Trial Memorandum due on or before December 13, 2016. He further requests this Honorable Court keep the December 14, 2016 pretrial conference date for the reasons above stated.
Respectfully submitted,
/s/_________
Samuel C. Stretton, Esquire
Attorney for Respondent,
David W. Tidd
301 S. High St., P.O. Box 3231
West Chester, PA 19381
(610) 696-4243
Attorney I.D. No. 18491 CERTIFICATE OF SERVICE
I hereby certify I am this date serving a copy of the foregoing Second Motion for an Extension of Time to File Pre-Trial Memorandum in the captioned matter upon the following persons in the manner indicated below.
Service by First Class Mail addressed as follows:
1. Elizabeth A. Flaherty, Esquire
Deputy Counsel
Judicial Conduct Board
Pennsylvania Judicial Center
601 Commonwealth Ave., Suite 3500
P.O. Box 62525
Harrisburg, PA 17106
(717) 234-7911
2. Melissa L. Norton, Esquire
Assistant Counsel
Judicial Conduct Board
Pennsylvania Judicial Center
601 Commonwealth Ave., Suite 3500
P.O. Box 62525
Harrisburg, PA 17106
(717) 234-7911
3. David W. Tidd12/1/16
11 Black Bear Run
Fleetwood, PA 19522
Date
Respectfully submitted,
/s/_________
Samuel C. Stretton, Esquire
Attorney for Respondent,
David W. Tidd
301 S. High St., P.O. Box 3231
West Chester, PA 19381
(610) 696-4243
Attorney I.D. No. 18491