IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

SARA SHANNON and ROSA PALACIOS 

and DEBRA CORBELLO, Individually and 

on behalf of all others similarly situated,

Plaintiffs,

v.

THE ALLSTATE CORPORATION,

Defendant.

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CIVIL ACTION NO. 1:20-cv-00448-LY

DEFENDANT’S UNOPPOSED MOTION FOR 

INCREASE IN PAGE LIMIT FOR DISPOSITIVE MOTION

Pursuant to Local Rule CV-7(d)(3), Defendant The Allstate Corporation (“Allstate”)

respectfully requests that the Court grant this Unopposed Motion to increase the page limit for 

Allstate’s dispositive motion to dismiss to 40 pages.

1

 Good cause exists for this Motion because 

the Complaint filed by Plaintiffs is complex, Allstate intends to make several dispositive 

arguments for its dismissal, and judicial efficiency will be served by allowing all dispositive 

arguments to be made in one answering brief.

Plaintiffs’ 40-page Complaint seeks certification of two separate classes premised on two 

causes of action alleging violations of Texas Insurance Code. Specifically, Plaintiffs allege that 

Allstate is engaged in two related and discriminatory schemes that involve unfairly charging 

higher premiums to its personal automotive insurance policyholders. 

Allstate intends to file a dispositive motion pursuant to Fed. R. Civ. P. 12(b) in response 

to the Complaint. As part of that motion, Allstate intends to invoke multiple subparts of Rule 

 

1 This Motion is made subject to and without waiving Allstate’s motion to dismiss Plaintiffs’ 

Complaint pursuant to Federal Rule of Civil Procedure 12(b)(2) based on lack of personal 

jurisdiction.

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12(b) to explain why each of Plaintiffs’ claims should be dismissed. The motion must address 

separate causes of action involving multiple alleged complex and comprehensive schemes and 

must also set forth the separate legal standards and authorities that apply to each of Plaintiffs’

causes of action. Having carefully considered the arguments it must make, Allstate believes the 

extra pages requested will allow it to adequately address the allegations of Plaintiffs’ Complaint 

and to make appropriate and legally supported arguments for dismissal. 

Allstate’s Motion to extend the page limit is not submitted for the purpose of delay, but 

rather so that justice may be served. Allstate intends to address all grounds for dismissal in one 

dispositive motion rather than successive motions, which will enable the Court to make one 

determination with respect to dismissal and thereby speed resolution of this lawsuit. Further, 

counsel for Allstate has conferred with counsel for Plaintiffs, and Plaintiffs’ counsel has 

indicated that Plaintiffs do not oppose this request. 

For all the foregoing reasons, Allstate respectfully requests that the Court enter an order 

granting Allstate’s Motion and increase its page limit for a dispositive motion to 40 pages. 

Dated: June 23, 2020 Respectfully submitted,

/s/ Amy L. Ruhland

Amy L. Ruhland (Rudd)

Texas Bar No. 24043561

DLA PIPER LLP

401 Congress Avenue, Suite 2500

Austin, TX 78701-3799

Telephone: 512-457-7220

Facsimile: 512-721-2220

amy.ruhland@dlapiper.com

ATTORNEYS FOR DEFENDANT THE 

ALLSTATE CORPORATION

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CERTIFICATE OF SERVICE

I hereby certify that on the 23rd day of June, 2020, I electronically filed the foregoing 

with the clerk of the court by using the CM/ECF system which will send a notice of electronic 

filing to:

ATTORNEYS FOR PLAINTIFFS

/s/ Amy L. Ruhland

Amy L. Ruhland (Rudd)

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