On June 19, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Nayer, Gautam,
and
Texas Southern University,
for DISCRIMINATION
in the District Court of Harris County.
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C. A. No. 2019-42312
GAUTAM NAYER In The
Plaintiff, District Court
Harris County, Texas
TEXAS SOUTHERN UNIVERSITY
Defendant Judicial District
THIRD JOINT MOTION TO CONTINUE FEBRUARY 8, 2021 TRIAL SETTING
Plaintiff Gautam Nayer, and Defendant, Texas Southern University (“TSU”), (collectively,
the “Parties”), file this Third Joint Motion to Continue February 8, 2021 Trial Setting, and would
respectfully show the Court as follows:
This lawsuit was filed on June 19, 2019, and is currently set for trial on February 8,
, pursuant to the Court’s Order Resetting Trial dated July 16, 2020.
The Parties have conferred and are in agreement to extend the discovery deadline from
October 9, 2020, to January 11, 2021 due to: the effects of the novel COVID 19 pandemic including
closed law offices, remote work from home with limited resources, and excessive dockets of both legal
counsels due to increased litigation and delays in other cases both legal counsels are scheduled for jury
trials in other cases in October and November; and the Parties’ need for additional time to engage in
discovery due to the multitude of legal allegations presented by Plaintiff. Attached is Exhibit “A”, the
Parties’ Rule 11 Agreement on extension of deadlines in the Court’s Docket Control Order.
In light of the extension of the discovery deadline, and as reflected in Exhibit “A” the
Parties are also in agreement to extend subsequent deadlines in the Court’s Docket Control Order and
have agreed upon the following proposed deadlines:
Challenges to Expert Testimony: January 11
Pleadings: January 11
Dispositive Motions and Pleas:
evidence motions for summary March 15
judgment may only be heard after this date
All dispositive motions or pleas must be March 15, 2021
heard
Based on the agreement to extend the above deadlines, the Parties respectfully request the
Court to continue the February , 2021 trial setting to May 3, 202 , with docket call set for April 26,
The Parties ask the Court to sign the proposed Amended Agreed Docket Control Order to
promote the efficient resolution of this case. The Parties attach a proposed Amended Agreed Docket
Control Order as Exhibit “ ”.
The extension of these deadlines is not for delay but is sought so that justice may be
done.
The Parties respectfully request that this Court grant this Motion for the reasons set forth above.
Respectfully submitted
/s/ Ellen Sprovach (with permission) /s/ Summer R. Lee______________
ELLEN SPROVACH SUMMER R. L
Texas Bar No. 24000672 Assistant Attorney General
ellen@rosenberglaw.com Texas Bar No. 24046283
ROSENBERG | SPROVACH General Litigation Division
3518 Travis, Suite 200 P.O. Box 12548, Capitol Station
Houston, Texas 77002 Austin, Texas 78711
(713) 960 (512) 475 4031 | FAX: (512) 320
(713) 621 6670 (Facsimile) summer.lee@oag.texas.gov
ATTORNEY CHARGE ATTORNEYS FOR DEFENDANT
FOR PLAINTIFF
Based on the timing of the deadline for dispositive motions, the first available trial date that is in compliance with the
Court’s Procedures is April 19, 2021 The Court’s Procedures require that a motion for summary judgment be set for
hearing at least one month before trial, and that submission and hearing dates for motions for summary judgments be held
on Mondays at 11 a.m. In order to give the Court adequate time to rule upon any dispositive motions, the Parties
respectfully request that the trial be set for May 3, 2021
Document Filed Date
October 06, 2020
Case Filing Date
June 19, 2019
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C. A. No. 2019-42312 GAUTAM NAYER In The Plaintiff, District Court Harris County, Texas TEXAS SOUTHERN UNIVERSITY Defendant Judicial District THIRD JOINT MOTION TO CONTINUE FEBRUARY 8, 2021 TRIAL SETTING Plaintiff Gautam Nayer, and Defendant, Texas Southern University (“TSU”), (collectively, the “Parties”), file this Third Joint Motion to Continue February 8, 2021 Trial Setting, and would respectfully show the Court as follows: This lawsuit was filed on June 19, 2019, and is currently set for trial on February 8, , pursuant to the Court’s Order Resetting Trial dated July 16, 2020. The Parties have conferred and are in agreement to extend the discovery deadline from October 9, 2020, to January 11, 2021 due to: the effects of the novel COVID 19 pandemic including closed law offices, remote work from home with limited resources, and excessive dockets of both legal counsels due to increased litigation and delays in other cases both legal counsels are scheduled for jury trials in other cases in October and November; and the Parties’ need for additional time to engage in discovery due to the multitude of legal allegations presented by Plaintiff. Attached is Exhibit “A”, the Parties’ Rule 11 Agreement on extension of deadlines in the Court’s Docket Control Order. In light of the extension of the discovery deadline, and as reflected in Exhibit “A” the Parties are also in agreement to extend subsequent deadlines in the Court’s Docket Control Order and have agreed upon the following proposed deadlines: Challenges to Expert Testimony: January 11 Pleadings: January 11 Dispositive Motions and Pleas: evidence motions for summary March 15 judgment may only be heard after this date All dispositive motions or pleas must be March 15, 2021 heard Based on the agreement to extend the above deadlines, the Parties respectfully request the Court to continue the February , 2021 trial setting to May 3, 202 , with docket call set for April 26, The Parties ask the Court to sign the proposed Amended Agreed Docket Control Order to promote the efficient resolution of this case. The Parties attach a proposed Amended Agreed Docket Control Order as Exhibit “ ”. The extension of these deadlines is not for delay but is sought so that justice may be done. The Parties respectfully request that this Court grant this Motion for the reasons set forth above. Respectfully submitted /s/ Ellen Sprovach (with permission) /s/ Summer R. Lee______________ ELLEN SPROVACH SUMMER R. L Texas Bar No. 24000672 Assistant Attorney General ellen@rosenberglaw.com Texas Bar No. 24046283 ROSENBERG | SPROVACH General Litigation Division 3518 Travis, Suite 200 P.O. Box 12548, Capitol Station Houston, Texas 77002 Austin, Texas 78711 (713) 960 (512) 475 4031 | FAX: (512) 320 (713) 621 6670 (Facsimile) summer.lee@oag.texas.gov ATTORNEY CHARGE ATTORNEYS FOR DEFENDANT FOR PLAINTIFF Based on the timing of the deadline for dispositive motions, the first available trial date that is in compliance with the Court’s Procedures is April 19, 2021 The Court’s Procedures require that a motion for summary judgment be set for hearing at least one month before trial, and that submission and hearing dates for motions for summary judgments be held on Mondays at 11 a.m. In order to give the Court adequate time to rule upon any dispositive motions, the Parties respectfully request that the trial be set for May 3, 2021