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Unopposed MOTION to Extend Time Expert Designations filed by Schyler Grodman with Brief/Memorandum in Support. (Attachments: # 1 Proposed Order) (Ramirez-Martinez

Grodman v. Texas Tech University Health Sciences Center, No. 5:23-cv-00210 (N.D. Tex.) · Dkt. 40 · 2025-06-05 · PDF

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

Case 5:23-cv-00210-H

Document 40

Filed 06/05/25

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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 TO EXTEND DEADLINE TO DESIGNATE
EXPERTS AND MODIFY CORRESPONDING DEADLINES
Plaintiff Schyler Grodman, M.D. (“Plaintiff”) files this Unopposed Motion to Extend
Deadline to Designate Experts and Modify Corresponding Deadlines (the “Motion”), and
respectfully states as follows:
1.

The current Scheduling Order (ECF No. 37) sets the following deadlines:
a. Initial Expert Designation and Report: June 6, 2025
b. Responsive Expert Designation and Report: July 2, 2025
c. Rebuttal Expert Designation: 30 days after responsive designation
d. Close of Discovery: August 8, 2025
e. Deadline to File Dispositive Motions and Daubert Motions: August 8, 2025

2.

Plaintiff respectfully requests a 14-day extension of the Initial Expert Designation

and Report deadline, from June 6, 2025 to June 20, 2025. Plaintiff further requests that the
following deadlines be extended by the same amount of time:
a. Responsive Expert Designation and Report: from July 2, 2025 to July
16, 2025;
b. Rebuttal Expert Designation: from August 1, 2025 to August 15, 2025;
and

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c. Close of Discovery and Deadline to File Dispositive and Daubert
Motions: from August 8, 2025 to August 22, 2025.
3.

This extension is necessary to allow adequate time to complete expert evaluations,

prepare reports, and complete related discovery. The issues in this case involve overlapping fact
and expert testimony that require careful development.
4.

This is the Plaintiff’s first request for such an extension. The requested extension

will not prejudice the Defendant nor affect any deadlines in this case. All pretrial and trial
deadlines, including the December 8, 2025 trial date, will remain unchanged.
5.

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

Defendant is unopposed to this request for extension of time.
6.

Counsel for Plaintiff has conferred with counsel for Defendant, who confirmed that

Defendant is unopposed to this Motion.
7.

This Motion is made in good faith and not for the purpose of delay. The requested

extensions will not prejudice either party and will assist in the efficient resolution of the case.
8.

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

WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully requests that the Court
extend the following deadlines: Initial Expert Designation and Report to June 20, 2025;
Responsive Expert Designation and Report to July 16, 2025; Rebuttal Expert Designation to
August 15, 2025; Close of Discovery and Dispositive/Daubert Motion Deadline to August 22,
2025.

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Case 5:23-cv-00210-H

Date: June 5, 2025

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Filed 06/05/25

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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 June 4-5, 2025 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 June 5, 2025.
/s/ Jeffrey M. Tillotson
Jeffrey M. Tillotson

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