Williams v. All Web Leads, Inc.

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

NOTICE Second Joint Motion to Temporarily Abate All Deadlines by Joe Williams

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UNITED STATES DISTRICT COURT 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. § SECOND JOINT MOTION TO TEMPORARILY ABATE ALL DEADLINES 1. Plaintiff Joe Williams and Defendant All Web Leads, Inc. ("Defendant" or "AWL") jointly request that the Court temporarily—for 14 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 14 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. Date: July 19, 2019 Respectfully submitted, ANDERSON ALEXANDER, PLLC /s/ Clif Alexander Clif Alexander Fed. ID #1138436 Tex. Bar #24064805 clif@a2xlaw .com Austin W. Anderson Fed. ID #777114 Tex. Bar #24045189 austin@a2xlaw.com Lauren E. Braddy Fed. ID #1122168 Tex. Bar #24071993 lauren@a2xlaw.com Alan Clifton Gordon Fed. ID #19259 Tex. Bar #00793838 cgordon@a2xlaw.com Carter T. Hastings Fed. ID #3101064 Tex. Bar #24101879 carter@a2xlaw.com 819 N. Upper Broadway Corpus Christi, Texas 78401 361.452.1279 phone 361.452.1284 fax Attorneys in Charge for Plaintiff CORNELL SMITH MIERL BRUTOCAO BURTON, LLP /s/ Steve Mierl Steve Mierl Tex. Bar #00795529 smierl@cornellsmith.com Andrew J. Broadaway Tex. Bar #24082332 abroadaway@cornellsmith.com Attorneys in Charge for Defendant Second Joint Motion To Temporarily Abate All Deadlines Page 2 of 3 CERTIFICATE OF SERVICE I hereby certify that on July 19, 2019, I electronically filed the foregoing document with the clerk of the court for the U.S. District Court, Western District of Texas, using the electronic case filing system of the court. The electronic case filing system sent a "Notice of Electronic Filing" to the attorneys of record who have consented in writing to accept this Notice as service of this document by electronic means. /s/ Clif Alexander Clif Alexander Second Joint Motion To Temporarily Abate All Deadlines Page 3 of 3