Williams v. All Web Leads, Inc.

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

Second MOTION for Extension of Time to File Response/Reply 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. § AGREED MOTION FOR SECOND EXTENSION OF RESPONSE DEADLINE 1. Plaintiff Joe Williams respectfully requests that the Court briefly extend Plaintiff's deadline to respond to the Motion to Dismiss (Clerk's Doc. No. 5) of Defendant All Web Leads, Inc.. The Court granted an initial agreed extension (Clerk's Doc. No. 7) via text entry on May 30, 2019. That initial extension¾until June 13, 2019¾was sought to allow the parties to explore a possible resolution of the matter without further Court intervention. Since the Court granted that initial extension, Defendant provided material and information¾relevant to assist in exploring such a resolution¾to Plaintiff on June 11, 2019 (Defendant's HR contacts had been on vacation). The parties intend to engage in further discussions about resolving this case without further Court intervention the week of June 17, 2019. 2. Upon consultation with counsel for Defendant, Defendant is unopposed to the extension sought in this Motion. 3. Doe these reasons, Plaintiff requests a new response deadline of June 20, 2019. 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: June 13, 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 and the Putative Class Members Agreed Motion for Second Extension of Deadline Page 2 of 3 CERTIFICATE OF SERVICE I hereby certify that on June 13, 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 Agreed Motion for Second Extension of Deadline Page 3 of 3