Case 3:12-cv-00796-JJB-EWD Document 196

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UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF LOUISIANA
JESSIE HOFFMAN, ET AL.
Plaintiff
CHRISTOPHER SEPULVADO
Intervenor
v.
BOBBY JINDAL, ET AL.
Defendants

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Civil Action No. 12-796-JJB-EWD

UNOPPOSED MOTION TO CONTINUE
STATUS CONFERENCE AND EXTEND STAY
MAY IT PLEASE THE COURT:
NOW INTO COURT, through undersigned counsel, come Defendants, Louisiana
Department of Public Safety and Corrections, James M. LeBlanc, Secretary of Louisiana
Department of Public Safety and Corrections in his official capacity, Darrel Vannoy, Warden of
Louisiana State Penitentiary in his official capacity, and James “Jimmy” Cruze, Jr., Assistant
Warden of Louisiana State Penitentiary in his official capacity, (collectively “Defendants”) who
move this Court to continue the status conference presently set for July 11, 2016, and, further,
extend the stay and terms of Consent Orders ( Rec. Docs. 178 and 188), for eighteen months or
until January 8, 2018.
1.
In support of the motion, undersigned counsel represents the following:

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2.
On May 20, 2016, a telephone status conference was held before the Honorable
Magistrate Judge Erin Wilder-Doomes with all parties participating through counsel of record.
(Rec. Doc. 195.)
3.
Counsel discussed the status of the case. (Rec. Doc. 195)
4.
The Court questioned counsel about the Consent Order entered on June 23, 2015, staying
all proceedings in this matter through July 11, 2016, as well as imposing a stay of any executions
of any Plaintiffs, and extending the temporary restraining order in effect with regard to the
execution of Christopher Sepulvado. (Rec. Doc. 195).
5.
Counsel were in agreement that a continuance of the stay for another year was
appropriate.
6.
In accordance with Magistrate Wilder-Doomes’ order, undersigned counsel conferred
with her clients and confirmed that they do not object to a stay.
7.
Undersigned counsel also conferred with counsel for the Plaintiffs, Michael Rubenstein,
who agreed, on behalf of the Plaintiffs, that he does not object to a stay. Mr. Rubenstein further
agreed that given that a twelve month stay would put all parties back in the position of dealing
with a legislative session and possible conflicts resulting from same, it would be prudent to
extend the stay for eighteen months or until approximately January 8, 2018.

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Defendants request this continuance and extension of the stay because the facts and
issues that are involved in this proceeding continue to be in a fluid state, meaning that it would
be a waste of resources and time to litigate this matter at present time.
WHEREFORE Defendants pray that this Court continue the status conference set for July
11, 2016, and extend the stay and terms of the Consent Orders previously entered by this Court
through January 8, 2018.

RESPECTFULLY SUBMITTED:
JEFF LANDRY
ATTORNEY GENERAL

BY: _/s/Elizabeth Baker Murrill _________________
ELIZABETH BAKER MURRILL (LBA #20685)
ASSISTANT ATTORNEY GENERAL
DEPARTMENT OF JUSTICE
CIVIL DIVISION
1885 North Third Street, 6th Floor
Post Office Box 94005
Baton Rouge, Louisiana 70804-9005
Telephone No. 225-326-6000
Facsimile No. 225-326-6098
E-Mail: murrille@ag.louisiana.gov
Attorney for Defendants, Louisiana Department of Public
Safety and Corrections, James M. LeBlanc, Secretary of
Louisiana Department of Public Safety and Corrections in
his official capacity, Darrel Vannoy, Warden of Louisiana
State Penitentiary in his official capacity, and James
“Jimmy” Cruze, Jr., Assistant Warden of Louisiana State
Penitentiary in his official capacity

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CERTIFICATE OF SERVICE
I do hereby certify that, on this 31st day of May 2016, the foregoing pleading was filed
electronically with the Clerk of Court using the CM/ECF system which gives notice of filing to
all counsel of record at the following email address:
Michael D. Rubenstein – mrubenstein@liskow.com
Cecelia Trenticosta Kappel – ceceliat@thejusticecenter.org
Mercedes Hardy Montagnes – mercedsm@thejusticecenter.org
Nicholas J. Tenticosta – nicktr@bellsouth.net
Letty S. DiGiulio – letty@lettydigiulio.com
Jonathan Samuel Sweeney – sam@cpcpl.org
Douglas Gist Swenson – swensond@ag.state.la.us
David Glen Sanders – sandersd@ag.state.la.us
James E. Boren- jboren@joneswalker.com
Gary Patrick Clements – gclements@cpcpl.org
James L. Hilburn – jamesh@swllp.com
Jeffrey K. Cody –jeffreyc@scwllp.com
Edmond Wade Shows – wade@scwllp.com
Grant Guillot – grantg@scwllp.com

/s/Elizabeth Baker Murrill
Elizabeth Baker Murrill