Williams v. All Web Leads, Inc.

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

NOTICE of Third Joint Motion to Temporarily Abate 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. § THIRD JOINT MOTION TO TEMPORARILY ABATE DEADLINES Plaintiff Joe Williams and Defendant All Web Leads, Inc. ("Defendant" or "AWL") jointly request that the Court allow the parties another brief period to finalize and formalize their settlement agreement. The parties anticipate needing another week to file notice with the Court of the dismissal of this matter. Therefore, the parties request an additional seven days' abatement of all deadlines imposed by both the Federal Rules of Civil Procedure and this Court's Local Rules and previously entered Orders. 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: September 24, 2019 Respectfully submitted, ANDERSON ALEXANDER, PLLC /s/ Clif Alexander Clif Alexander Fed. ID #1138436 Tex. Bar #24064805 clif@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 Third Joint Motion to Abate and for Continuance Page 2 of 3 CERTIFICATE OF SERVICE I hereby certify that on September 24, 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 Third Joint Motion to Abate and for Continuance Page 3 of 3