Alvarez v. Emergency Site Protection, LLC et al

Western District of Texas, txwd-5:2018-cv-01298

Agreed MOTION for Extension of Time to File a Proposed Scheduling Order by Sanchez Oil & Gas Corporation. Motions referred to Judge Elizabeth S. Chestney.

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IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION JOSUE ALVAREZ, § Individually and on behalf of all others § similarly situated, § § Plaintiff, § § v. § CASE NO. 5:18-cv-01298-FB-ESC § GRYPHON HOLDCO, LLC, and § SANCHEZ OIL & GAS CORPORATION, § § Defendants. § AGREED MOTION FOR EXTENSION OF TIME FOR THE PARTIES TO PROPOSE SCHEDULING ORDER Plaintiff Josue Alvarez, individually and on behalf of all others similarly situated, and Defendants Gryphon Holdco, LLC ("Gryphon") and Sanchez Oil & Gas Corporation ("Sanchez") (collectively, the "Parties") file this Agreed Motion for Extension of Time in the above-captioned action. The Parties request that the Court extend the July 17, 2019 deadline to provide their proposed scheduling order until after the Court rules on Defendant Gryphon's Motion to Dismiss and Compel Arbitration (ECF No. 30) and Defendant Sanchez's Motion to Compel Arbitration (ECF No. 41). This extension is justified because the motions to compel are presently before the Court, and the Court's ruling may moot the need for entry of a scheduling order at this time. This extension is not sought for the purpose of delay, but so that justice may be done. Therefore, the Parties request that the deadline for providing the Court with a proposed scheduling order be extended until 14 days after the Court's ruling on Defendants' motions to compel (ECF Nos. 30 and 41), and that submission of a proposed scheduling order shall only be required if the Court does not compel the Parties to arbitration. 1 Dated: July 17, 2019 Respectfully submitted, ANDERSON ALEXANDER, PLLC AKIN GUMP STRAUSS HAUER & FELD LLP By: /s/ Clif Alexander, by perm. BGP By: /s/ Brian G. Patterson Clif Alexander Brian G. Patterson Texas Bar No. 24064805 Texas Bar No. 24042974 Lauren E. Braddy Scott L. Friedman Texas Bar No. 24071993 Texas Bar No. 24087543 Alan Clifton Gordon 1111 Louisiana, 44th Floor Texas Bar No. 00793838 Houston, Texas 77002-5200 Telephone: 713.220.5800 Carter T. Hastings Telecopier: 713.236.0822 Texas Bar No. 24101879 COUNSEL FOR DEFENDANT 819 North Upper Broadway SANCHEZ OIL & GAS CORPORATION Corpus Christi, Texas 78401 Telephone: (361) 452-1279 Facsimile: (361) 452-1284 CHAMBERLAIN HRDLICKA WHITE WILLIAMS & AUGHTRY COUNSEL FOR PLAINTIFF AND THE PUTATIVE CLASS MEMBERS By: /s/ Annette Idalski, by perm. BGP Annette Idalski Texas Bar No. 00793235 191 Peachtree St. NE, 46th Floor Atlanta, Georgia 30303-1747 Telephone: 404-658-5386 Telecopier: 404-658-5387 and Stephanie M. Gilliam Texas Bar No. 24083071 1200 Smith Street, Suite 1400 Houston, Texas 77002 Telephone: 713-654-9608 Facsimile: 713-658-2553 COUNSEL FOR DEFENDANT GRYPHON HOLDCO, LLC 2 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing has been served in accordance with the Federal Rules of Civil Procedure on this 17th day of July, 2019. _/s/ Brian G. Patterson_________________ Brian G. Patterson 3