STIPULATION AND ORDER TO EXTEND THE DEADLINE TO RESPOND TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT

(First Request)

JAMES C. MAHAN, District Judge.

COMES NOW, Plaintiff RUDY RIVERA, by and through his counsel of record Mitchell S. Bisson, Esq. of the Callister Law Group, and Defendant CORRECTIONS CORPORATION OF AMERICA ("CoreCivic"), by and through its counsel of record Jacob. B. Lee, Esq. of Struck Love Bojanowski & Acedo, PLC, and hereby respectfully submit this Stipulation and Order to Extend the Deadline to Respond to Defendants' Motion for Summary Judgment (the "Stipulation"). This Stipulation is made in accordance with LR IA 6-1, LR IA 6-2, LR 7-1, and LR 26-4 of the Local Rules of this Court. This is the first request for an extension of time to file the Plaintiff's response Opposition to Defendants' Motion for Summary Judgment and subsequent Reply from Defendant.

Defendants filed the Motion for Summary Judgment [Dkt. 47] on May 3, 2019 and Plaintiffs' response is currently due May 24, 2019. The instant extension is requested because Plaintiffs' counsel unexpectedly had a trial run three days longer than expected, and as a result, requires additional time to prepare the response Opposition to Defendants' Motion. This request for an extension of time is not sought for any improper purpose or other purpose of delay. It is further requested that the deadline to file Defendant's Reply be extended as well.

Upon agreement by and between all parties hereto as set forth herein, the undersigned respectfully requests this Court grant an extension of time, up to and including May 29, 2019, for Plaintiff to file an Opposition to Defendants' Motion to Dismiss [Dkt. 47], and to grant an extension of time, up to and including June 14, 2019 for Defendant to file a Reply to Plaintiff's response Opposition.

ORDER

IT IS SO ORDERED.