Case: 61CO1:18-cv-02329 Document #: 214 Filed: 06/19/2020 Page 1 of 4

IN THE COUNTY COURT OF THE FIRST JUDICIAL DISTRICT OF

RANKIN COUNTY, MISSISSIPPI

DANIEL SHOPE PLAINTIFF

VS. CAUSE NO. 18-2329

Dr. MICHAEL WINKELMANN,et.al DEFENDANTS

and his personal capacity;
and NEWSOUTH NEUROSPINE

__________________________________________________________________

PLAINTIFF’S REPLY TO DEFENDANTS RESPONSE TO PLAINTIFF’S

MOTION FOR SUMMARY JUDGMENT
DOC. [212]
____________________________________________________________________________

COMES NOW, Plaintiff Daniel Shope, by and through his attorney of record and files this reply

in response to Defendants response in opposition to Plaintiff’s motion for summary judgment,

Plaintiff’s Doc. [207].

As such Plaintiff makes the following argument.

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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3. First, likely unbeknownst to Defendants, June 19th is celebrated by African American, of

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,

with varying official recognition.” Therefore, the celebrating of Plaintiff’s counselor’s

heritage is important to the African American movement in America this date.

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

repetitive before the court on Tuesday.

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.

RESPECTFULLY SUBMITTED THIS THE 19TH DAY OF JUNE, 2020

Plaintiff Daniel Shope

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 Case: 61CO1:18-cv-02329 Document #: 214 Filed: 06/19/2020 Page 3 of 4

/s/Abby Robinson (MSB 105157)

ABBY ROBINSON LAW FIRM PLLC.

227 E. PEARL STREET
JACKSON, MISSISSIPPI 39201
TELEPHONE: (601) 321-9343
FACSIMILE: (601) 487-6326
Email: arobinsonlawfirm@yahoo.com
Email: abby@askabbylaw.com

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.

This the 19th day of June, 2020.

/s/Abby Robinson (MSB 105157)

ABBY ROBINSON LAW FIRM PLLC.
227 E. PEARL STREET
JACKSON, MISSISSIPPI 39201
TELEPHONE: (601) 321-9343
FACSIMILE: (601) 487-6326
Email: arobinsonlawfirm@yahoo.com
Email: abby@askabbylaw.com

H. Wesley Williams, III

Markow Walker, PA
Post Office Box 13669
Jackson, MS 39236-3669
wwilliams@markowwalker.com
Attorney for Defendant

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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
cwalker@markowwalker.com
Attorney for Defendant

Roy Smith
Daniel Coker Daniel Coker
4400 Old Canton Road, Suite 400
Jackson, MS 39211
601-969-7607
rsmith@danielcoker.com

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