V. Quicken Loans, Inc.

Western District of Texas, txwd-5:2019-cv-00697

Unopposed MOTION for Extension of Time to File Answer by Quicken Loans, Inc.

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION PABLO E. GAY AND ANNA J. SUBIA § AKA ANNA J. SUBIA-GAY § § Plaintiffs, § § v. § Civil Action Number: 5:19-CV-00697-OLG § QUICKEN LOANS, INC. § § Defendant. § § § § DEFENDANT'S UNOPPOSED MOTION TO EXTEND DEADLINE TO RESPOND TO COMPLAINT NOW COMES Defendant, Quicken Loans, Inc. ("Defendant"), and request an extension of the deadline to respond to the Plaintiffs' Original Petition until July 31, 2019. In support of this Motion, Defendant states as follows: 1. Plaintiffs Pablo E. Gay and Anna J. Subia aka Anna J. Subia-Gay. (collectively, "Plaintiffs") filed their Original Petition against Defendant on or about May 31, 2019 in the District Courts of Bexar County, Texas. 2. On or about June 14, 2019, the matter was removed from the 407th Judicial District Court of Bexar County, Texas under cause no. 2019CI10993, to the United States District Court, for the Western District of Texas, San Antonio Division. 3. On or about July 29, Plaintiffs agreed to extend Defendant's deadline to respond to the Complaint until August 10, 2019, while the parties continue settlement negotiations. Defendant's Unopposed Motion to Extend Deadline to Respond to Complaint Page 1 DA 234159.1 WHEREFORE, Defendant requests this Court to enter an order extending the deadline to respond to the Complaint until August 10, 2019, and granting such further and additional relief as the Court deems just and proper. Respectfully submitted this 29th day of July, 2019. By: /s/ Jacob Sparks Jacob Sparks Texas Bar No. 24066126 SPENCER FANE LLP 5700 Granite Parkway, Suite 650 Plano, Texas 75024 Tel: (972) 324-0300 Fax: (972) 324-0301 Email: JSparks@SpencerFane.com ATTORNEYS FOR DEFENDANT QUICKEN LOANS, INC. CERTIFICATE OF CONFERENCE The undersigned certifies that plaintiff's counsel is not opposed to the relief requested in the foregoing Motion. By: /s/ Jacob Sparks Jacob Sparks Defendant's Unopposed Motion to Extend Deadline to Respond to Complaint Page 2 DA 234159.1 CERTIFICATE OF SERVICE The undersigned certifies that a copy of the foregoing Motion was filed on July 29, 2019, using the Court's electronic filing system. According to Local Rule 5.1, "The notice of electronic filing that is automatically generated by the Court's electronic filing system constitutes service of the document on those registered as filing users of the system." By: /s/ Jacob Sparks Jacob Sparks Defendant's Unopposed Motion to Extend Deadline to Respond to Complaint Page 3 DA 234159.1