UNOPPOSED MOTION for Extension of Time to File Response to 24 MOTION to Dismiss PLAINTIFF'S FIRST AMENDED COMPLAINT , 25 MOTION to Dismiss PLAINTIFF'S FIRST AMENDED¶
Wells v. Texas Tech University, et al, No. 5:23-cv-00060 (N.D. Tex.) · Dkt. 29 · 2023-07-13 · PDF
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Case 5:23-cv-00060-H Document 29 Filed 07/13/23 Page 1 of 4 PageID 259 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 Plaintiff, Cara Wells files this unopposed motion seeking to extend the deadline to respond to Defendants’ Motions to Dismiss [Dkt. 24 and 25]. 1. Defendants filed their respective motions on July 6, 2023, and the deadline to respond is July 27, 2023. 2. Plaintiff’s Counsel requests an additional seven (7) days to file Plaintiff’s response to Defendants’ Motion to Dismiss or to amend the Original Complaint. 3. Plaintiff’s Counsel consulted with Defendants’ Counsel, and Defendants agree to an extension of time. 4. 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. Plaintiff’s Motion for Extension Page 1 of 4 Case 5:23-cv-00060-H Document 29 Filed 07/13/23 Page 2 of 4 PageID 260 WHEREFORE, Plaintiff respectfully requests the Court to grant a 7-day extension to respond to Defendants’ Motions to Dismiss or amend the original Complaint by August 3, 2023. Dated: July 13, 2023 Respectfully submitted, BREWER, ATTORNEYS & COUNSELORS By: /s/ William A. Brewer IV Matthew H. Davis William A. Brewer IV (admitted pro hac vice) mhd@brewerattorneys.com wbb@brewerattorneys.com 1717 Main Street, Suite 5900 Dallas, Texas 75201 T: (214) 653-4000 F: (214)653-1015 COUNSEL FOR PLAINTIFF CARA WESSELS WELLS Plaintiff’s Motion for Extension Page 2 of 4 Case 5:23-cv-00060-H Document 29 Filed 07/13/23 Page 3 of 4 PageID 261 CERTIFICATE OF CONFERENCE I hereby certify that William A. Brewer IV, Counsel for Cara Wells, conferred with Kristin Erickson, counsel for Defendants, via email on July 13, 2023, on the matter in this motion. Ms. Erickson stated that Defendants are unopposed. /s/ William A. Brewer, IV WILLIAM A. BREWER IV Plaintiff’s Motion for Extension Page 3 of 4 Case 5:23-cv-00060-H Document 29 Filed 07/13/23 Page 4 of 4 PageID 262 CERTIFICATE OF SERVICE I hereby certify that the foregoing document was served on all counsel of record on July 13, 2023, via the court’s electronic filing system. /s/ William A. Brewer, IV WILLIAM A. BREWER IV Plaintiff’s Motion for Extension Page 4 of 4