Case: 1:15-cv-01046-SO Doc #: 21 Filed: 09/09/15 1 of 3.

PageID #: 556

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF OHIO
EASTERN DIVISION

UNITED STATES OF AMERICA,

Plaintiff,
v.
CITY OF CLEVELAND,
Defendant.

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CASE NO.: 1:15cv01046

JUDGE: SOLOMON OLIVER, JR.

JOINT MOTION TO EXTEND

DATE FOR SELECTION
OF MONITOR

The Parties jointly move the Court for approval to extend by fourteen days the date by
which a Monitor must be selected, from September 10, 2015 to September 24, 2105. Pursuant to
the Parties Settlement Agreement, which was adopted as an order of the Court on June 12, 2015,
the Parties have 90 days from that date to agree on a Monitor (Dkt. # 7, &353). The Settlement
Agreement provides for modifications to its terms by agreement of the Parties, with Court
approval, and states that modifications are encouraged where they will further the purpose of the
Agreement. (Dkt. # 7, &398).
Selecting a Monitor is critical to the successful implementation of the Settlement
Agreement. The Parties have made significant progress toward that goal; we have received and
reviewed over 25 applications from interested groups, and interviewed a number of finalists.

Case: 1:15-cv-01046-SO Doc #: 21 Filed: 09/09/15 2 of 3. PageID #: 557

This process has been, however, very time-consuming, and to allow for its completion as
effectively as possible, the Parties agree that a brief extension of fourteen days is required.
Conclusion
For the foregoing reasons, the Parties request that the Court approve an extension of
fourteen days for selection of a Monitor.
Respectfully submitted,

STEVEN M. DETTELBACH
United States Attorney
Northern District of Ohio

BARBARA A. LANGHENRY (0038838)

Director of Law
City of Cleveland

s/Carole S. Rendon____________________
By: CAROLE S. RENDON (0070345)
First Assistant U.S. Attorney
Northern District of Ohio

_________________________
By: GARY S. SINGLETARY
Chief Counsel
JOSEPH F. SCOTT
Chief Assistant Director of Law
City of Cleveland
601 Lakeside Avenue, Room 106
Tel: (216)664-2800
Fax: (216)664-2663
Email: blanghenry@city.cleveland.oh.us
Email:gsingletary@city.cleveland.oh.us
Email: jscott@city.cleveland.oh.us

MICHELLE HEYER (0065723)

HEATHER TONSING VOLOSIN (0069606)
Assistant U.S. Attorneys
Northern District of Ohio
400 United States Court House
801 West Superior Avenue
Cleveland, Ohio 44113-1852
Tel. (216) 622-3600
Email: Carole.Rendon@usdoj.gov
Email: Michelle.Heyer@usdoj.gov
Email: Heather.Tonsing.Volosin@usdoj.gov

Case: 1:15-cv-01046-SO Doc #: 21 Filed: 09/09/15 3 of 3. PageID #: 558

VANITA GUPTA
Principal Deputy Assistant Attorney General
Civil Rights Division

s/Judy C. Preston______________________
JUDY C. PRESON
Acting Chief
Special Litigation Section
EMILY A. GUNSTON (CA 218035)
Special Counsel
RASHIDA OGLETREE
T. JACK MORSE
Trial Attorneys
United States Department of Justice
Civil Rights Division
Special Litigation Section
950 Pennsylvania Avenue, NW
Washington, DC 20530
Tel. (202) 514-6255; Fax. (202) 514-4883
Email: Emily.Gunston@usdoj.gov
Email: Rashida.Ogletree@usdoj.gov
Email: Jack.Morse@usdoj.gov

CERTIFICATE OF SERVICE
I hereby certify that on September 9, 2015, I served the foregoing document entitled Joint
Motion to Extend Date for Selection of Monitor via the Courts ECF system to all counsel of
record.
s/Michelle L. Heyer
MICHELLE L. HEYER