IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

MIDLAND DIVISION 

YADIRA URANGA, 

Plaintiff, 

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v. § CIVIL ACTION NO. 7:20-CV-21 

 § 

MIDLAND ODESSA URBAN 

TRANSIT DISTRICT, CITY OF 

ODESSA, TEXAS, CITY OF 

MIDLAND, TEXAS, RATP DEV 

USA, INC., and MIDLANDODESSA TRANSIT 

MANAGEMENT, INC., 

Defendants. 

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§ JURY DEMANDED 

JOINT AGREED MOTION TO EXTEND EXPERT, DISCOVERY 

AND DISPOSITIVE MOTIONS DEADLINES 

TO THE HONORABLE JUDGE JAMES WESLEY HENDRIX: 

Plaintiff, YADIRA URANGA and Defendants MIDLAND ODESSA URBAN 

TRANSIT DISTRICT, CITY OF ODESSA, TEXAS, CITY OF MIDLAND, TEXAS, RATP 

DEV USA, INC., and MIDLAND-ODESSA TRANSIT MANAGEMENT, INC. (collectively 

the “Parties”) hereby request that the Court grant an extension of time for the Defendants’ expert 

deadline, the discovery deadline and the dispositive motions deadline currently set for October 

28, 2020, November 4, 2020 and December 4, 2020. 

1. The Court entered its amended scheduling order on August 5, 2020 (Dkt. 28) 

which set the Defendants’ expert deadline on October 28, 2020, the discovery 

deadline on November 4, 2020 and the dispositive motions deadline on December 

4, 2020. This case is currently set for a jury trial on August 2, 2021. 

Case 7:20-cv-00021-DC Document 35 Filed 10/14/20 Page 1 of 4
JOINT AGREED MOTION TO EXTEND DEADLINES – PAGE 2 

2. The Parties have been engaged in written discovery and depositions. However, 

due to scheduling issues related to the number of parties involved in this case and 

other settings, additional depositions need to be conducted prior to trial. 

Specifically, Plaintiff’s deposition has not yet been taken and needs to be taken 

prior to the close of discovery. Plaintiff also needs to take Defendants’ expert 

deposition and Defendants need to take Plaintiff’s expert deposition. The Parties 

request the discovery deadline be extended to December 31, 2020 so that 

discovery may be completed. 

3. Defendants’ expert needs an additional two weeks to finalize his report due to 

scheduling issues in other cases and the niche nature of the legal issues in this 

dispute. The Parties request the Court to extend the Defendants’ expert deadline 

to November 11, 2020. 

4. The Parties also request an extension of the dispositive motions deadline to permit 

motions to be filed once discovery is closed. The Parties request the Court to 

extend the dispositive motions deadline to February 1, 2021. 

5. Counsel for the Parties have conferred and agreed to the extensions requested in 

this Motion. The Parties’ request does not impact the current pretrial deadlines or 

the date this case is set for trial. 

ACCORDINGLY, the Parties request that the Court grant the extensions requested 

herein, extend the Defendants’ expert deadline to November 11, 2020, the discovery deadline to 

December 31, 2020, extend the dispositive motions deadline to February 1, 2021, and for such 

other relief to which the Parties may show themselves justly entitled. 

Case 7:20-cv-00021-DC Document 35 Filed 10/14/20 Page 2 of 4
JOINT AGREED MOTION TO EXTEND DEADLINES – PAGE 3 

Respectfully submitted, 

/s/ Christopher McGreal 

Christopher P. McGreal 

State Bar No. 24051774 

cmcgreal@drtx.org

Rachel B. Cohen-Miller 

State Bar No. 24064301 

rmiller@drtx.org

Disability Rights Texas 

1420 Mockingbird Lane, Suite 450 

Dallas, Texas 75247 

(214) 845-4069 

(214) 630-3472 – Facsimile 

ATTORNEYS FOR PLAINTIFF 

/s/ Amanda N. Crouch 

Jon Mark Hogg 

State Bar No. 00784286 

jmhogg@jw.com

Amanda N. Crouch 

State Bar No. 24077401 

JACKSON WALKER L.L.P. 

136 W. Twohig, Suite B 

San Angelo, Texas 76903 

(325) 481-2560 

(325) 481-2585 – Facsimile 

JACKSON WALKER L.L.P. 

112 East Pecan Street, Suite 2400 

San Antonio, Texas 78205 

acrouch@jw.com 

(210) 978-7700 

(210) 978-7790 – Facsimile 

ATTORNEYS FOR DEFENDANTS 

MIDLAND ODESSA URBAN TRANSIT 

DISTRICT, RATP DEV USA, INC., 

and MIDLAND-ODESSA TRANSIT 

MANAGEMENT, INC. 

Case 7:20-cv-00021-DC Document 35 Filed 10/14/20 Page 3 of 4
JOINT AGREED MOTION TO EXTEND DEADLINES – PAGE 4 

/s/ Aaron M. Dorfner 

Aaron M. Dorfner 

State Bar No. 24040824 

adorfner@cbtd.com

Melinda D. Hamm 

State Bar No. 24059924 

mhamm@cbtd.com

COTTON, BLEDSOE, TIGHE & DAWSON 

A Professional Corporation 

P.O. Box 2776 

Midland, Texas 79702 

(432) 684-5782 

(432) 682-3672 – Facsimile 

ATTORNEYS FOR DEFENDANT, 

CITY OF MIDLAND, TEXAS 

/s/ Daniel C. Jones 

Daniel C. Jones 

Senior Assistant City Attorney 

State Bar No. 24110838 

dcjones@odessa-tx.gov

CITY OF ODESSA 

411 W. 8th Street 

P.O. Box 4398 

Odessa, Texas 79760 

(432) 335-3289 

ATTORNEYS FOR DEFENDANT, 

CITY OF ODESSA, TEXAS 

CERTIFICATE OF SERVICE 

This is to certify that on the 14th day of October, 2020, I electronically filed the foregoing 

with the Clerk of Court using the CM/ECF system which will send notice of such filing to all 

attorneys of record on file. 

/s/ Amanda N. Crouch 

Amanda N. Crouch 

Case 7:20-cv-00021-DC Document 35 Filed 10/14/20 Page 4 of 4