STIPULATION AND [PROPOSED] ORDER TO EXTEND SUMMARY JUDGMENT AND CASE MANAGEMENT DEADLINES

WILLIAM ALSUP, District Judge.

STIPULATION

Plaintiff Tio Dinero Sessoms and Defendant Darren Bright, by and through their undersigned counsel, respectfully request that the Court enter the following stipulation pursuant to Federal Rule of Civil Procedure 6(b) and Civil Local Rule 6-2 for a brief extension of (1) the opposition and reply brief deadlines and hearing date for Defendant's motion for summary judgment; and (2) the case management statement deadline and case management conference.

In support of this stipulation, the undersigned parties provide the following facts:

1. On May 5, 2015, this Court issued an order setting Defendants' deadline to file a motion for summary judgment on June 4, 2015. Due to the withdrawal of Plaintiff's former pro bono counsel, the Court referred the case to the Federal Pro Bono Project and granted Plaintiff a four-week extension of the deadline to respond. The order also stated that the Court "would also consider a reasonable motion to extend or to continue deadlines (where good cause is shown) brought by new appointed pro bono counsel." (Dkt. 91.)

2. On June 1, 2015, the Court appointed Ivor Samson, Bonnie Lau and Jessica Duggan, all of Dentons US LLP, as pro bono counsel for Plaintiff pursuant to 28 U.S.C. 1915(e)(1) and the Court's Federal Pro Bono Project guidelines. The Court set the briefing schedule on Defendants' motion for summary judgment as follows: Defendants' motion for summary judgment due on June 4, 2015; Plaintiff's opposition brief due on July 16, 2015; and Defendants' reply brief due on July 23, 2015. The Court scheduled the hearing on the motion for summary judgment on August 13, 2015 at 8:00 a.m. (Dkt. 96.)

3. The Court also ordered the parties to file a joint case management statement pursuant to Civil Local Rule 16-9 no later than August 6, 2015, and scheduled a case management conference on August 13, 2015 at 8:00 a.m. (Dkt. 96).

4. Defendant Bright filed a "Supplemental Motion for Summary Judgment" on June 4, 2015. (Dkt. 98.)

5. Good cause exists to extend the opposition and reply deadlines and hearing date for Defendant Bright's Supplemental Motion for Summary Judgment, as well as the case management statement deadline and case management conference. Ms. Lau has a Federal Circuit appeal brief due on July 6 and a summary judgment motion due on July 8. Ms. Lau also has a previously-scheduled work trip to Japan from July 13-24 for an investigation in another matter. Ms. Duggan has a post-trial brief due on June 8 and closing arguments in that same trial on June 22. In addition, Ms. Duggan has previously-scheduled out-of-state family commitments from July 2-9 and July 30-August 3. Counsel for Defendant Bright, Susan Kawala, has a prepaid vacation from August 9-16, which conflicts with the current hearing date.

In light of the above facts, the parties jointly request that the Court briefly extend the summary judgment and case management deadlines, and enter the following stipulation as an Order of the Court:

A. Plaintiff shall file his opposition brief by August 17, 2015.

B. Defendant shall file his reply brief by August 24, 2015.

C. The hearing on Defendant Bright's Supplemental Motion for Summary Judgment shall be on September 10, 2015 at 8:00 a.m.

D. The case management conference shall be on September 10, 2015 at 8:00 a.m.

E. The parties shall file a joint case management statement no later than September 3, 2015.

PROPOSED ORDER

Pursuant to Stipulation and for good cause shown,

IT IS SO ORDERED.