STIPULATION AND [Proposed] ORDER TO CONTINUE PRETRIAL FILING DEADLINE TO JULY 25, 2018

HAYWOOD S. GILLIAM, JR., District Judge.

Following extensive good faith meet and confer, the parties jointly request a one-week continuance of the July 18, 2018 pretrial filing deadline (for a revised statement of the case, revised proposed jury instructions, and revised proposed voir dire questions per Dkt. No. 161), for the following reasons. As reflected in Plaintiff's trial availability schedule (Doc. 160), both Plaintiff's trial counsel are on vacation July 11 through 18. As reflected in Defendants' trial availability calendar (Doc. 159), defense lead counsel Lowhurst is on vacation for the period June 1 - July 11, and DAG Plank is on vacation June 14 and 15, and from July 2 through 6. Therefore, under the current schedule it is not possible for both lead counsel to jointly review and finalize the pre-trial filings before the July 18 due date. Specifically, while the parties can, and will, prepare draft documents in anticipation of a July 18th deadline, Defendant's lead counsel (Lowhurst) will not be able to review the filings until July 12, by which time all of Plaintiff's counsel will be absent. Should the Court allow, the parties stipulate to a one-week extension for the filing of the revised statement of the case, revised proposed jury instructions, and revised proposed voir dire questions, to July 25, 2018.

ATTESTATION

I attest under penalty of perjury that concurrence in the filing of this document has been obtained from Deborah Kochan.

[Proposed] ORDER

Good cause appearing, the Stipulation Regarding Continuance of Pretrial Filing Deadline to July 25, 2018, is hereby approved.