Paez v. Childrens Health System of Texas — Entry #18: Unopposed MOTION to Extend Time to Mediate filed by Alexander Paez
Case: Paez v. Childrens Health System of Texas txnd · 3:23-cv-02243
filed October 10, 2023
What this document is
Docket entry #18 · filed May 24, 2024
Unopposed MOTION to Extend Time to Mediate filed by Alexander Paez (Attachments: (1) Proposed Order) (Gasper, Travis)
Who is involved
- Childrens Health System of Texas
- Paez
Why we have it
We follow this case because it names a company we track, although that company is not a party:
- Applied Digital: its name “Applied Digital Corporation” appears in a filing in this case.
…LLC 90 3:23-cv-01805-E McConnell v. Applied Digital Corporation et al 91 3:23-cv-01832-8 Doe v. Dallas…
A free copy from the RECAP archive of federal court filings (mirrored at the Internet Archive), retrieved October 23, 2026. Federal court filings are public records.
Document text
3 page(s), 6,480 characters, converted from the PDF's text layer · plain text.
Full text
Case 3:23-cv-02243-E Document 18 Filed 05/24/24 Page 1 of 3 PageID 105
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
ALEXANDER PAEZ, §
§
Plaintiff, §
§
v. § Civil Action No. 3:23-cv-2243-E
§
CHILDREN’S HEALTH SYSTEM OF §
TEXAS, §
§
Defendant. §
PLAINTIFF’S UNOPPOSED MOTION TO EXTEND MEDIATION DEADLINE
Pursuant to the December 27, 2023 Scheduling Order [Dkt. 10], Plaintiff Alexander Paez
(“Plaintiff”) moves the Court to extend the deadline for the Parties to mediate and states as follows:
I. BACKGROUND
This is an employment discrimination case filed pursuant to the FMLA and ADA, arising from
Plaintiff’s employment with Defendant. Defendant filed its Answer to Plaintiff’s Original Complaint
on December 11, 2023 [Dkt. 6]. Courtenay L. Bass of Gilbert Mediation Group is the agreed mediator
in this case [Dkt. 9; Dkt. 13]. On December 27, 2023, the Court issued a Scheduling Order establishing
various case deadlines, including mediation, completion of discovery, and the due date to file
dispositive motions [Dkt. 13]. Since then, the Parties requested and the Court granted one extension
to the Scheduling Order [Dkt. 14; Dkt. 15]. The current mediation deadline is June 17, 2024 [Dkt. 15].
This motion does not seek a continuance of the deadline for completion of discovery (October
15, 2024) or the deadline to file dispositive motions (November 15, 2024), or of the trial date (three-
week docket beginning April 1, 2025).
PLAINTIFF’S UNOPPOSED MOTION TO EXTEND MEDIATION DEADLINE Page 1
Case 3:23-cv-02243-E Document 18 Filed 05/24/24 Page 2 of 3 PageID 106
II. GROUNDS FOR CONTINUANCE
Plaintiff’s deposition took place on April 24, 2024. Plaintiff took the deposition of one of
Defendant’s corporate representatives on May 1, 2024. The deposition of Defendant’s other corporate
representative was noticed and scheduled for May 9, 2024. The afternoon of May 8, 2024, Defendant
produced additional documents that Plaintiff’s counsel needed more time to review before the May 9
deposition. Plaintiff’s counsel notified defense counsel of such and sent an amended notice that set
the deposition for May 29, 2024. On May 17, defense counsel notified Plaintiff’s counsel that “May
29 is not available” and requested Plaintiff’s availability from July 15–24.
Mediation is currently set for June 17, 2024—selected by the Parties so that mediation would
take place after depositions were completed.1 Because it appears that defense counsel or Defendant’s
corporate representative is not available for deposition until July 15–24, mediation must necessarily
occur later than it is currently scheduled, after the current mediation deadline. The Parties have already
been in contact with the mediator’s office to check availability for a mediation date after July 15–24.
The mediator currently has nine dates available before the deadline proposed/requested here.
The requested extension does not affect any other deadlines in this case, including the
deadlines for discovery or dispositive motions, or of the trial date.
III. RELIEF REQUESTED
Considering the foregoing factors, Plaintiff respectfully requests an extension of the mediation
deadline under the Scheduling Order to August 23, 2024. This is the second request for an extension
of a Scheduling Order deadline in this case. The request is not made for purposes of delay, but so that
justice may be done.
1
“The Parties anticipate that mediation would be more productive after the Parties’ depositions are
completed.” See Joint Motion to Extend Mediation Deadline [Dkt. 14 at 2].
PLAINTIFF’S UNOPPOSED MOTION TO EXTEND MEDIATION DEADLINE Page 2
Case 3:23-cv-02243-E Document 18 Filed 05/24/24 Page 3 of 3 PageID 107
IV. CONCLUSION
WHEREFORE, Plaintiff Alexander Paez respectfully prays that this Court grant this
Unopposed Motion to Extend Mediation Deadline and continue the current mediation deadline to
August 23, 2024.
Respectfully submitted,
GASPER LAW PLLC
By: /s/ Travis Gasper
Travis Gasper
Texas Bar No. 24096881
1408 N. Riverfront Blvd., Suite 323
Dallas, Texas 75207
Phone: (469) 663-7736
Fax: (833) 957-2957
Email: [email protected]
ATTORNEY FOR PLAINTIFF
CERTIFICATE OF CONFERENCE
Plaintiff’s counsel conferred with counsel for Defendant, who indicated Defendant is
unopposed to the relief requested herein.
s/ Travis Gasper
Travis Gasper
CERTIFICATE OF SERVICE
I hereby certify that on May 24, 2024, I electronically filed the foregoing with the Clerk of
Court using the CM/ECF system, which will send a notice of electronic filing to all counsel of record.
s/ Travis Gasper
Travis Gasper
PLAINTIFF’S UNOPPOSED MOTION TO EXTEND MEDIATION DEADLINE Page 3