JOINT STIPULATION FOR EXTENSION OF TIME TO ANSWER COMPLAINT AND [PROPOSED] ORDER

(FIRST REQUEST)

JAMES C. MAHAN, Magistrate Judge.

Plaintiff Steven R. Davis, pro se ("Davis," or the "Plaintiff'), and Telecom Management Group, Inc., an Illinois corporation doing business as Unitel ("TMGI," or the "Defendant"),1 through its undersigned counsel of record, agree that upon the Court's approval, TMGI's response to Plaintiff's Complaint,2 currently due on August 9, 2018,3 shall be due two weeks from that date, on August 23, 2018, for the reasons set forth below:

1. Defendant's response to Plaintiff's Complaint presently is due on August 9, 2017.4

2. Defendant only just recently retained counsel to respond to this action, and Defendant's counsel has requested additional time from Plaintiff to become familiar with the matter before the Court prior to responding to Plaintiffs Complaint.

3. Following an e-mail exchange on August 8, 2018, Plaintiff agreed to allow Defendant a two-week extension of time to respond to the Complaint.

4. Accordingly, Plaintiff and Defendant stipulate and agree that, upon the Court's approval, Defendant's response to Plaintiffs Complaint shall be due on August 23, 2018_

5. The time for Defendant to answer or respond to Plaintiffs Complaint has not yet elapsed, and this stipulation is supported by good cause as demonstrated in the foregoing paragraphs.

6. Pursuant to Local Rule 6-1, this is Plaintiff and Defendant's first request for an extension of this deadline; the parties seek this extension in good faith and not for the purposes of delay. Further granting this brief two-week extension shall not prejudice any party to this action.

Dated this 9th of August, 2018, by the undersigned Plaintiff and counsel for Defendant.

[PROPOSED] ORDER

It is here ORDERED that, good cause appearing the parties' foregoing stipulation is GRANTED, and Defendant's response to Plaintiff's Complaint shall be due on August 23, 2018.