IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

DARNELL COOPER,

Plaintiff,

v.

KARYN MORGAN et al.,

Defendants.

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Case No. 12-cv-5625

Judge Edmond E. Chang

Magistrate Judge Young B. Kim

PLAINTIFF’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE 

RESPONSE TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT 

Plaintiff Darnell Cooper (“Plaintiff”), by his counsel, Paul Hastings LLP, hereby 

respectfully moves this Court for an Order extending the deadline for Plaintiff to file his 

response to the Motion for Summary Judgment of Defendants Karyn Morgan, Angelique 

Matuzas, Kent Ocupe, and Stacey Headlee by 14 days, to and including November 10, 2015, and 

in support thereof states as follows:

1. Plaintiff, who is currently incarcerated at Stateville Correctional Center 

(“Stateville”), filed this action on December 27, 2012. 

2. On September 28, 2015, Defendants filed their Motion for Summary Judgment. 

Pursuant to this Court’s order of September 14, 2015, Plaintiff’s response to Defendants’ Motion 

is currently due on October 27, 2015. 

3. Since receiving Defendants’ Motion, Plaintiff and his counsel have been working 

diligently to prepare a response. However, due to logistical difficulties in communicating with 

Case: 1:12-cv-05625 Document #: 170 Filed: 10/20/15 Page 1 of 3 PageID #:1653
an incarcerated client at Stateville, Plaintiff and his counsel require additional time to prepare the 

response and the necessary supporting documents. 

4. Plaintiff therefore requests a brief, 14-day extension of his deadline to file a 

response to Defendants’ Motion, to and including November 10, 2015. 

5. This is Plaintiff’s first request for an extension. Defendants previously sought 

and received a 14-day extension of their deadline to file the Motion. 

6. Plaintiff has conferred with counsel for Defendants, who advised that Defendants 

have no objection to the relief requested herein. 

WHEREFORE, Plaintiff Darnell Cooper respectfully requests that this Court enter an 

Order extending Plaintiff’s deadline to file a response to Defendants’ Motion for Summary

Judgment by 14 days, to and including November 10, 2015. 

Dated: October 20, 2015

 

 Respectfully submitted,

 /s/ Christopher F. Allen

Jon A. Geier

Christopher F. Allen

Alex Maturi

Paul Hastings LLP

71 South Wacker Dr., Suite 4500

Chicago, IL 60606

Telephone: (312) 499-6000

Facsimile: (312) 499-6100

Email: christopherallen@paulhastings.com

Counsel for Plaintiff Darnell Cooper

Case: 1:12-cv-05625 Document #: 170 Filed: 10/20/15 Page 2 of 3 PageID #:1653
CERTIFICATE OF SERVICE

I hereby certify that on the 20th day of October 2015, I caused to be served upon 

all parties of record a true and correct copy of Plaintiff’s Unopposed Motion for Extension of 

Time to File Response to Defendants’ Motion for Summary Judgment by filing such 

document through the Court’s Electronic Case Filing System.

/s/ Christopher F. Allen 

Christopher F. Allen

Paul Hastings LLP

71 South Wacker Dr., Suite 4500

Chicago, IL 60606

Telephone: (312) 499-6000

Facsimile: (312) 499-6100

Email: christopherallen@paulhastings.com

Counsel for Plaintiff Darnell Cooper

Case: 1:12-cv-05625 Document #: 170 Filed: 10/20/15 Page 3 of 3 PageID #:1653