MOTION for Extension of Time to File Response/Reply to 5 MOTION to Dismiss for Lack of Jurisdiction filed by Schyler Grodman (Attachments: # 1 Proposed Order)¶
Grodman v. Texas Tech University Health Sciences Center, No. 5:23-cv-00210 (N.D. Tex.) · Dkt. 8 · 2023-11-14 · PDF
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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS LUBBOCK DIVISION SCHYLER Z. GRODMAN, M.D., Plaintiff, v. TEXAS TECH UNIVERSITY HEALTH SCIENCES CENTER, Defendant. § § § § § § § § § § Civil Action No. 5:23-cv-00210-H PLAINTIFF’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT’S PARTIAL MOTION TO DISMISS Plaintiff Schyler Grodman, M.D. files this Unopposed Motion for Extension of Time (the “Motion”) seeking an extension of seven days for Plaintiff’s deadline to respond to Defendant Texas Tech University Health Sciences Center’s Partial Motion to Dismiss [ECF Doc. 5], and in support thereof, would respectfully show the Court the following: 1. Plaintiff Schyler Grodman, M.D. (“Plaintiff”) filed its Original Complaint against Defendant on September 7, 2023 [ECF Doc. 1]. 2. Defendant Texas Tech University Health Sciences Center (“Defendant”) filed its Partial Motion to Dismiss on October 4, 2023 [ECF Doc. 5]. 3. Plaintiff’s current deadline to file its response to Defendant’s Partial Motion to Dismiss is November 15, 2023. 4. Plaintiff requests an extension of time of seven days to file its response to the Partial Motion to Dismiss—from November 15, 2023, to November 22, 2023. 5. This is the Plaintiff’s second request for an extension. 1 6. Good cause exists for Plaintiff’s request because Plaintiff requires additional time to amend its complaint, which will make Defendant’s Partial Motion to Dismiss moot. 7. Good cause exists for Plaintiff’s request because the attorneys responsible for preparing Plaintiff’s response brief have been and will be required to devote time to additional matters from November 15, 2023 to November 22, 2023, including various proceedings, hearings, and mediations. 8. The requested extension will not prejudice the Defendant nor affect any deadlines in this case. 9. Plaintiff’s counsel has conferred with Defendant’s counsel and confirmed that Defendant is unopposed to this request for extension of time. 10. Accordingly, Plaintiff respectfully requests the Court grant this Motion and extend its deadline to respond to Defendant’s Partial Motion to Dismiss from November 15, 2023, to (and including) November 22, 2023. 11. This request is not for delay but so justice may be done. 12. WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully requests that the Court extend the deadline by which it must respond to Defendant’s Partial Motion to Dismiss by seven days from November 15, 2023, to (and including) November 22, 2023. 2 Date: November 14, 2023 Respectfully Submitted, /s/ Jeffrey M. Tillotson Jeffrey M. Tillotson State Bar No. 20039200 jtillotson@tillotsonlaw.com Enrique Ramirez-Martinez State Bar No. 24122158 eramirez@tillotsonlaw.com TILLOTSON JOHNSON & PATTON 1201 Main Street, Suite 1300 Dallas, Texas 75202 (214) 382-3041 Telephone (214) 292-6564 Facsimile ATTORNEYS FOR PLAINTIFF CERTIFICATE OF CONFERENCE Under Local Rule 7.1, I certify that I have complied with Local Rule 7.1 and conferred with Joseph Keeney, counsel for Defendant, via email and telephone on November 13, 2023, and via email on November 14, 2023, regarding the substance of the foregoing motion. Counsel for Plaintiff is unopposed to the motion. /s/ Enrique Ramirez Enrique Ramirez CERTIFICATE OF SERVICE The undersigned hereby certifies that the foregoing was electronically filed with the Clerk of the Court using the CM/ECF system on November 14, 2023. /s/ Jeffrey M. Tillotson Jeffrey M. Tillotson 3