Hernandez v. Global Prisoner Services, LLC D/b/a Texas Prisoner Transportation Services

Western District of Texas, txwd-5:2019-cv-00374

MOTION for Leave to Exceed Page Limitation by PTS of America, LLC.

Interested in this case?

Current View

Full Text

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION AMANDA HERNANDEZ and DAVID) RINCON, Individually and On Behalf of) All Others Similarly Situated,)) Plaintiffs,) Case No. 5:19-cv-00374-FB vs.)) GLOBAL PRISONER SERVICES, LLC) d/b/a TEXAS PRISONER) TRANSPORTATION SERVICES,) PTS OF AMERICA, LLC, and) RYAN WHITTEN Defendants. PTS OF AMERICA, LLC'S MOTION TO EXCEED PAGE LIMITATION PTS of America, LLC (PTS), files this Motion to Exceed Page Limitation with respect to PTS's Motion to Dismiss, or in the Alternative, Motion to Transfer Venue, and respectfully states the following: 1. The Local Rules of the Western District of Texas state that a dispositive motion is limited to twenty (20) pages. W.D. TEX. L.R. CV-7(d)(3). Because PTS's Motion to Dismiss, or in the Alternative, Motion to Transfer Venue, is longer than 20 pages, PTS requests leave of this Court to exceed the page limitation. 2. Good cause exists for extending the page limitation. Rather than file a separate Motion to Dismiss, or in the Alternative Motion to Transfer Venue, PTS files this in its Motion to Dismiss, so that it is all contained in one motion. PTS made the best effort to keep the motion concise, and requests permission to file its Motion to Dismiss, or in the Alternative, Motion to Transfer Venue, not to exceed 30 pages. PTS's Motion to Dismiss, or in the Alternative Motion to Transfer Venue, is attached as Exhibit 1. 1 245719 3. PTS conferred with Plaintiffs regarding this motion. Amanda Hernandez and David Rincon are not opposed to the relief requested in this motion. PTS did not confer with separate defendants Ryan Whitten and Global Prisoner Services, LLC d/b/a Texas Prisoner Transportation Services, as those defendants have not appeared as of the filing of PTS's requested relief. CONCLUSION AND PRAYER PTS respectfully requests that the Court grant it leave to exceed the page limitation for PTS's Motion to Dismiss, or in the Alternative, Motion to Transfer Venue. Respectfully submitted, Mary E. Buckley, Texas Bar # 24101571 Gregory J. Northen, Ark. Bar # 20111891* CROSS, GUNTER, WITHERSPOON & GALCHUS, P.C. 500 President Clinton Avenue, Suite 200 Little Rock, Arkansas 72201 Phone: 501-371-9999 / Fax: 501-371-0035 E-mail: mbuckley@cgwg.com /gnorthen@cgwg.com *Pro Hac Vice Pending 2 245719