MOTION for Extension of Time to File Response to 15 MOTION to Dismiss, 16 MOTION to Dismiss or to Amend the Original Complaint filed by Cara Wells (Attachments: # 1¶
Wells v. Texas Tech University, et al, No. 5:23-cv-00060 (N.D. Tex.) · Dkt. 17 · 2023-06-02 · 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 17 Filed 06/02/23 Page 1 of 4 PageID 115 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. § § § § § § § § CAUSE NO. 5:23-CV-00060-H PLAINTIFF’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANTS’ MOTION TO DISMISS OR TO AMEND THE ORIGINAL COMPLAINT Plaintiff, Cara Wells files this unopposed motion seeking to extend the deadline to respond to Defendants’ Motions to Dismiss [Dkt. 15 and 16] or amend the Original Complaint. 1. Defendants filed their respective motions on May 18, 2023, and the deadline to respond or amend the complaint as of right is June 8, 2023. 2. Plaintiff’s Counsel requests an additional fourteen (14) days to file Plaintiff’s response to Defendants’ Motion to Dismiss or to amend the Original Complaint. 3. On May 31, 2023, Plaintiff’s Counsel consulted with Defendants’ Counsel, and, on June 1, 2023, Defendants agreed to an extension to June 22, 2023, for Plaintiff to either respond to Defendants’ Motion to Dismiss or amend the Original Complaint. 4. This motion is not filed for the purposes of delay but only to ensure that the papers filed with the Court are appropriate and will assist the Court in the resolution of the pending matter. Case 5:23-cv-00060-H Document 17 Filed 06/02/23 Page 2 of 4 PageID 116 WHEREFORE, Plaintiff respectfully requests that the Court grant a 14-day extension of the deadline to respond to Defendants’ Motions to Dismiss or amend the original Complaint to June 22, 2023. Dated: June 2, 2023 Respectfully submitted, BREWER, ATTORNEYS & COUNSELORS /s/ William A. Brewer IV WILLIAM A. BREWER IV (admitted pro hac vice) 750 Lexington Avenue, Floor 14 New York, NY 10022 wbb@brewerattorneys.com Telephone: (212)489-1400 Facsimile: (212)751-2849 COUNSEL FOR PLAINTIFF Case 5:23-cv-00060-H Document 17 Filed 06/02/23 Page 3 of 4 PageID 117 CERTIFICATE OF CONFERENCE I hereby certify that William A. Brewer IV, Counsel for Cara Wells, conferred with Kirstin Erickson, counsel for Defendants, via email on June 1, 2023, on the matter in this motion. Ms. Erickson stated that Defendants are unopposed. /s/ William A. Brewer, IV WILLIAM A. BREWER IV Case 5:23-cv-00060-H Document 17 Filed 06/02/23 Page 4 of 4 PageID 118 CERTIFICATE OF SERVICE I hereby certify that the foregoing document was served on all counsel of record on June 2, 2023, via the court’s electronic filing system. /s/ William A. Brewer, IV WILLIAM A. BREWER IV