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

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

Unopposed MOTION for Extension of Time to File Response/Reply as to [41] Motion to Dismiss for Failure to State a Claim and Incorporated Memorandum of Law by Amanda Hernandez. Motions referred to Judge Richard B. Farrer.

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UNITED STATES DISTRICT WESTERN DISTRICT OF TEXAS COURT SAN ANTONIO DIVISION AMANDA HERNANDEZ, § Individually and On Behalf of All § Others Similarly Situated, § § Plaintiff, § § v. § No. 5:19-cv-00374 § GLOBAL PRISONER SERVICES, § LLC d/b/a TEXAS PRISONER § TRANSPORTATION SERVICES, § § Defendant. § PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE A RESPONSE TO DEFENDANT RYAN WHITTEN'S MOTION DISMISS AND INCORPORATED MEMORANDUM OF LAW IN SUPPORT THEREOF Plaintiff Amanda Hernandez (referred to as "Plaintiff") requests that the Court continue the deadline for her to respond to Defendant Ryan Whitten's Motion Dismiss and Incorporated Memorandum of Law in Support Thereof (Dkt. 41) until November 25, 2019. On November 5, 2019, Defendant filed a Motion Dismiss and Incorporated Memorandum of Law in Support Thereof (Def.'s Mtn to Dismiss. (Dkt. 38).) Currently, Plaintiff's response to the motion is due on November 19, 2019. Based on an informal exchange of information, Hernandez believes that a resolution of the claim is possible. As a result, counsel would like to extend the current November 18, 2019 deadline. Plaintiff needs additional time to respond to the pending motion and respectfully requests the Court extend the deadline to file her response until November 25, 2019. For the foregoing reasons, Plaintiff respectfully requests that the Court extend Plaintiff's deadline to respond to Defendant's Motion Dismiss and Incorporated Memorandum of Law in Support Thereof. Defendant is unopposed to this request, provided that the deadline to reply is extended in the light of the Thanksgiving holiday. - 2 - Respectfully submitted, MOORE & ASSOCIATES By: Melissa Moore State Bar No. 24013189 Curt Hesse State Bar No. 24065414 Lyric Center 440 Louisiana Street, Suite 675 Houston, Texas 77002 Telephone: (713) 222-6775 Facsimile: (713) 222-6739 ATTORNEYS FOR PLAINTIFF CERTIFICATE OF CONFERENCE On November 19, 2019, Counsel conferred with Counsel for Defendant, who stated he was not opposed to this Motion. Melissa Moore CERTIFICATE OF SERVICE I hereby certify that on the 19th day of November in the year 2019, I filed this document with the Court's CM/ECF system which will send notification of such filing to all counsel of record. Melissa Moore - 3 -