Juneteenth Response Corrected
Juneteenth Response Corrected
Juneteenth Response Corrected
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COMES NOW, Plaintiff Daniel Shope, by and through his attorney of record and files this reply
1. Defendants have filed this response on this Friday June 19, 2020 at approximately 2:25p.m.
2. The Parties to this matter are scheduled for a hearing before this court Tuesday June 23, 2020
at 2:00 p.m. regarding both parties motion for summary judgment inter alia. As such,
Plaintiff avers that it is bad faith for Defendants to expect Plaintiff to properly respond to
Defendants argument today, Friday June 19, 2020 for the following reasons.
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Case: 61CO1:18-cv-02329 Document #: 214 Filed: 06/19/2020 Page 2 of 4
which the counsel is of the race, as the date of “Juneteenth is a holiday celebrating the
liberation of those who had been held as slaves in the United States. Originating in
Texas, it is now celebrated annually on the 19th of June throughout the United States,
4. Second, Because of Defendants bad faith in replying to Plaintiff’s motion for summary
judgment which was filed June 10, 2020, it is unreasonable for Defendants to believe that a
reasonable reply could be formulated and timely filed. Besides, any such argument will be
before the court in exactly (1) business day. Therefore, such reply as of today would only be
5. It follows that Plaintiff respectfully ask the Court to allow Plaintiff to argue the Plaintiff’s
position of summary judgment before the court on Tuesday June 23, 2020 as scheduled with
the court.
6. Moreover, Plaintiff respectfully request that the court allow Plaintiff to be excused from such
a reply this late i the day and on Plaintiff’s counsel heritage day. Plaintiff ask the court to
respect Plaintiff’s heritage today, especially since such a response was filed unreasonably
late in the day, and based on most of the United States media, all people must know that June
19th is celebrated by African Americans, Plaintiff avers that even the President of the United
States changed his calendar in observation of this black American Heritage day.
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CERTIFICATE OF SERVICE
I certify that I have filed the foregoing document with the Clerk of Court using the CM/EFC
system, which sent notification of that filing to all persons registered to receive service of this
case.
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Case: 61CO1:18-cv-02329 Document #: 214 Filed: 06/19/2020 Page 4 of 4
Chris J. Walker
Markow Walker, PA
Post Office Box 13669
Jackson, MS 39236-3669
[email protected]
Attorney for Defendant
Roy Smith
Daniel Coker Daniel Coker
4400 Old Canton Road, Suite 400
Jackson, MS 39211
601-969-7607
[email protected]
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