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Unopposed Motion for Extension of Time to File Answer filed by Lindsay Penrose, Samuel Prien, Texas Tech University (Attachments: # 1 Proposed Order Granting Motion for

Wells v. Texas Tech University, et al, No. 5:23-cv-00060 (N.D. Tex.) · Dkt. 7 · 2023-04-05 · PDF

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

Case 5:23-cv-00060-H

Document 7

Filed 04/05/23

Page 1 of 2

PageID 57

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
LUBBOCK DIVISION
CARA WESSELS WELLS,
Plaintiff
v.
TEXAS TECH UNIVERSITY, SAMUEL
PRIEN, LINDSAY PENROSE,
Defendants.

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CAUSE NO. 5:23-CV-00060-H

DEFENDANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME
TO RESPOND TO PLAINTIFF’S ORIGINAL COMPLAINT
Defendants Texas Tech University, Dr. Samuel D. Prien, and Dr. Lindsay Penrose
(collectively “Defendants”) file this unopposed motion seeking to extend the deadline to respond
to Plaintiff Cara Wessels Wells’s Complaint [Dkt.1].
1. Plaintiff filed her Original Complaint on March 22, 2023.
2. Defendant TTU was served with Plaintiff’s Original Complaint on March 28, 2023, and
the deadline to file a responsive pleading is due April 18, 2023.
3. Defendants Dr. Prien and Dr. Penrose were served on March 29, 2023, and the deadline
to file a responsive pleading is April 19, 2023.
4. The Office of the Attorney General has recently been retained to represent Defendants in
this matter, and accordingly additional time is needed to adequately prepare a defense.
5. Defendants’ Counsel consulted with Plaintiff’s Counsel, and Plaintiff agrees to an
extension of time.
6. This motion is not filed for the purposes of delay but only to ensure that the briefing
filed with the Court is appropriate and will assist the Court in the resolution of the pending matter.

Case 5:23-cv-00060-H

Document 7

Filed 04/05/23

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PageID 58

WHEREFORE, Defendants respectfully request the Court to grant a 30-day extension to
respond to Plaintiff’s Original Complaint, or by May 18, 2023.

Dated April 5, 2023

Respectfully submitted.

KEN PAXTON
Attorney General of Texas

/s/ Kirstin M. Erickson
KIRSTIN M. ERICKSON
Texas Bar No. 24134194
Assistant Attorney General

BRENT WEBSTER
First Assistant Attorney General
SHAWN COWLES
Deputy Attorney General for Civil Litigation
CHRISTOPHER D. HILTON
Chief for General Litigation Division

Office of the Attorney General
General Litigation Division
P.O. Box 12548, Capitol Station
Austin, TX 78711-2548
(512) 463-2120
(512) 320-0667 FAX
kirstin.erickson@oag.texas.gov
COUNSEL FOR DEFENDANTS

CERTIFICATE OF CONFERENCE
I hereby certify that Kirstin Erickson, Counsel for Texas Tech University, conferred with Ramon
Hernandez, counsel for Plaintiff, via email on April 4, 2023, on the matter in this motion. Mr. Hernandez
stated that Plaintiff is unopposed.
/s/ Kirstin M. Erickson
KIRSTIN M. ERICKSON

CERTIFICATE OF SERVICE
I hereby certify that the foregoing document was served on all counsel of record on April 5, 2023,
via the court’s electronic filing system.
/s/ Kirstin M. Erickson
KIRSTIN M. ERICKSON

Defendants’ Motion for Extension

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