Objection, 14 MOTION for Leave to File First Amended Complaint filed by Schyler Grodman (Attachments¶

Grodman v. Texas Tech University Health Sciences Center, No. 5:23-cv-00210 (N.D. Tex.) · Dkt. 17 · 2024-01-05 · PDF
Text extracted from the PDF; scanned pages were read by OCR. The PDF is the authoritative copy.
Case 5:23-cv-00210-H

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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.

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Civil Action No. 5:23-cv-00210-H

PLAINTIFF’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO
FILE REPLY TO DEFEENDANT’S RESPONSE TO PLAINTIFF’S MOTION FOR
LEAVE TO FILE FIRST AMENDED COMPLAINT
Plaintiff Schyler Grodman, M.D. files this Unopposed Motion for Extension of Time (the
“Motion”) seeking an extension of six days for Plaintiff’s deadline to reply to Defendant Texas
Tech University Health Sciences Center’s Response to Plaintiff’s Motion for Leave to File First
Amended Complaint [ECF Doc. 16], and in support thereof, would respectfully show the Court the
following:
1.

Plaintiff Schyler Grodman, M.D. (“Plaintiff”) filed his Motion for Leave to File

First Amended Complaint on December 4, 2023 [ECF Doc. 14], removing two claims for
discrimination and retaliation under the Americans with Disabilities Act and Texas Commission
on Human Rights and adding a Procedural Due Process claim as well as two claims under the
Rehabilitation Act against Defendant.
2.

Defendant Texas Tech University Health Sciences Center (“Defendant”) filed its

Response to Plaintiff’s Motion for Leave to File Plaintiff’s First Amended Complaint (the
“Response”) on December 22, 2023 [ECF Doc. 16], challenging the majority, but not all, of the
claims asserted against Defendant.

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Plaintiff’s current deadline to file its Reply to Defendant’s Response to Plaintiff’s

Motion for Leave to File First Amended Complaint (“Reply”) is January 5, 2023.
4.

Plaintiff requests an extension of time of six days to file its Reply—from January

5, 2024, to January 11, 2024.
5.

This is the Plaintiff’s first request for an extension for his Reply. Good cause exists

for Plaintiff’s request because Plaintiff requires additional time due to the intervening holidays,
because of the complexity of the issues raised by Defendant’s Response, and because the attorneys
responsible for preparing Plaintiff’s reply brief have been and will be required to devote time to
additional matters from January 2, 2024 to January 11, 2024, including various proceedings and
hearings.
6.

The requested extension will not prejudice the Defendant nor affect any deadlines

in this case.
7.

Plaintiff’s counsel has conferred with Defendant’s counsel and confirmed that

Defendant is unopposed to this request for extension of time.
8.

Accordingly, Plaintiff respectfully requests the Court grant this Motion and extend

its deadline file his Reply to Defendant’s Response to Plaintiff’s Motion for Leave to File First
Amended Complaint from January 5, 2024, to (and including) January 11, 2024.
9.

This request is not for delay but so justice may be done.

10.

WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully requests that

the Court extend the deadline by which he must file his Reply to Defendant’s Response to
Plaintiff’s Motion for Leave to File First Amended Complaint from January 5, 2024, to (and
including) January 11, 2024.

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Date: January 5, 2024

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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 on January 5, 2024, 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 Original Complaint and Jury Demand
was electronically filed with the Clerk of the Court using the CM/ECF system on January 5, 2024.
/s/ Jeffrey M. Tillotson
Jeffrey M. Tillotson

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