Williams v. All Web Leads, Inc.

Western District of Texas, txwd-5:2019-cv-00426

Joint MOTION to Temporarily Abate Deadlines by All Web Leads, Inc.

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION JOE WILLIAMS, Individually and § on Behalf of All Others Similarly § Situated § § Plaintiff, § § CIVIL ACTION NO. 5:19-cv-00426-DAE v. § § ALL WEB LEADS, INC. § § Defendant. § JOINT MOTION TO TEMPORARILY ABATE DEADLINES Plaintiff Joe Williams and Defendant All Web Leads, Inc. ("Defendant" or "AWL") jointly request that the Court temporarily—for 30 days—abate all deadlines imposed by both the Federal Rules of Civil Procedure and this Court's Local Rules and previously entered Orders. Specifically, the parties are actively conferring in exploration of a potential resolution of this matter without further Court intervention. The parties believe that, within 30 days, they will know whether the matter can be settled, or whether further litigation or arbitration is necessary. If settlement discussions are unsuccessful, the parties propose to resume the deadlines set by the Rules and this Court upon expiration of the 30 day period. This motion is not made for the purposes of delay or prejudice, but so that the interests of justice may be more fully served. Joint Motion to Temporarily Abate Deadlines Page 1 Respectfully submitted, ANDERSON ALEXANDER, PLLC CORNELL SMITH MIERL BRUTOCAO 819 N. Upper Broadway BURTON, LLP Corpus Christi, Texas 78401 1607 West Avenue Telephone: (361) 452-1279 Austin, Texas 78701 Telecopier: (361) 452-1284 Telephone: (512) 328-1540 Telecopy: (512) 328-1541 By:/s/ Clif Alexander______ By: /s/ Steve Mierl_____________ CLIF ALEXANDER Steve Mierl State Bar No. 24064805 smierl@cornellsmith.com clif@a2xlaw.com State Bar No. 00795529 ALAN CLIFTON GORDON Andrew J. Broadaway State Bar No. 00793838 abroadaway@cornellsmith.com cgordon@a2xlaw.com State Bar No. 24082332 ATTORNEYS FOR DEFENDANT ATTORNEYS FOR PLAINTIFFS Joint Motion to Temporarily Abate Deadlines Page 2