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MOTION for Extension of Time to File Response/Reply to 36 MOTION to Sever Claims against UT Defendants MOTION to Transfer Case out of District/Division as to Claims

Stewart v. Texas Tech University Health Sciences Center et al, No. 5:23-cv-00007-H (N.D. Tex.) · Dkt. 47 · 2023-10-27 · PDF

Text extracted from the PDF; scanned pages were read by OCR. The PDF is the authoritative copy.

Case 5:23-cv-00007-H

Document 47

Filed 10/27/23

Page 1 of 3

PageID 378

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
LUBBOCK DIVISION
George Stewart,
Plaintiff;
v.

Case No. 5:23-cv-0007-H

Texas Tech University Health
Sciences Center, et al.,
Defendants.
THE UNIVERSITY OF TEXAS DEFENDANTS’
UNOPPOSED MOTION FOR EXTENSION OF TIME
Defendants Dell Medical School at The University of Texas at Austin,
McGovern Medical School at The University of Texas Health Science Center at
Houston, the John Sealy School of Medicine at The University of Texas Medical
Branch (UTMB) at Galveston, the Long School of Medicine at The University of Texas
Health Science Center at San Antonio, The University of Texas Southwestern
Medical Center in Dallas, along with the officials at those institutions sued here in
their official capacities, 1 move to for an extension of time to respond to Plaintiff
George Stewart’s oppositions to their motion to dismiss (Doc. 35) and motion to sever
and transfer (Doc. 36).
The UT Defendants’ replies in support of their motions are currently due on
Tuesday, October 31, 2023 and the UT Defendants seek a brief extension until
Monday, November 6, 2023 to file their replies for good cause because this past
Wednesday evening, counsel for the UT Defendants’ car was broken into and his work
The individual UT Defendants are: Jay Hartzell, Claudia F. Lucchinetti, Steve Smith, Joel A.
Daboub, Giuseppe N. Colasurdo, John Hancock, Margaret C. McNeese, Charles P. Mouton, Jeffrey
Susman, Ruth E. Levine, Pierre W. Banks, William L. Henrich, Robert A. Hromas, Belinda Chapa
Gonzalez, Chiquita Collins, Daniel K. Podolsky, W.P. Andrew Lee, and Leah Schouten.

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Case 5:23-cv-00007-H

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computer and briefcase were stolen. Plaintiff George Stewart does not oppose the
relief requested in this motion.
Accordingly, the UT Defendants as this Court grant their request for a brief
extension of time to respond to Stewart’s oppositions to their motion to dismiss and
motion to sever and transfer.
Dated: October 27, 2023

Respectfully submitted,
/s/ Layne E. Kruse
Layne E. Kruse
(Texas Bar No. 11742550)
Shauna Johnson Clark
(Texas Bar No. 00790977)
Eliot F. Turner
(Texas Bar No. 24066224)
NORTON ROSE FULBRIGHT US LLP
1301 McKinney, Suite 5100
Houston, Texas 77010
Telephone: 713-651-5151
Telecopier: 713-651-5246
layne.kruse@nortonrosefulbright.com
shauna.clark@nortonrosefulbright.com
eliot.turner@nortonrosefulbright.com

Attorneys for the University of Texas Defendants

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Case 5:23-cv-00007-H

Document 47

Filed 10/27/23

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PageID 380

CERTIFICATE OF SERVICE
I certify that on October 27, 2023, I served a copy of this document on all
counsel of record by electronic means.
/s/ Layne Kruse
Layne Kruse
CERTIFICATE OF CONFERENCE
I certify that on October 26, 2023, I conferred with plaintiff’s counsel about the
relief requested in this motion and plaintiff’s counsel indicated that they were
unopposed to the relief requested in the motion.
/s/ Layne Kruse
Layne Kruse

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