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DEFENDANT’S UNOPPOSEDMOTION FOR LEAVE TO EXTEND TIME PAGE 1

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

SAN ANTONIO DIVISION

RONALD K. PAGE, on behalf of himself and 

all others similarly situated,

Plaintiffs,

v.

STATE FARM LIFE INSURANCE 

COMPANY,

Defendant.

Civil Action No. 5:20-cv-00617-FB

DEFENDANT’S UNOPPOSED MOTION FOR LEAVE TO EXTEND TIME TO FILE 

ITS REPLY IN SUPPORT OF ITS OBJECTIONS/APPEAL OF THE 

MAGISTRATE’S REPORT AND RECOMMENDATIONS AND ORDER [DKT. 137]

1. United States Magistrate Judge Elizabeth Chestney issued her Report and 

Recommendations as to Plaintiff’s Motion for Class Certification and Order as to State Farm’s 

Motion to Exclude Plaintiff’s expert on February 10, 2022. [Dkt. 137]. Following receipt of a oneweek extension from the Court, State Farm filed its objections to the Report and 

Recommendations, as well as its appeal of the Order, on March 3, 2022. [Dkt. 142]. Plaintiff filed 

a response on March 17, 2022. [Dkt. 145]. The time limit for filing a reply is 7 days after the 

response is filed. See Western District of Texas Local Rule CV-7(e). 

2. Separately, this Court has also granted the parties’ Joint Motion for Leave to Extend 

Time to Object to the Magistrate’s Report and Recommendations filed on March 16, 2022 as to 

State Farm’s Motion for Summary Judgment. In granting that extension request, the Court also 

found that “given the breadth of the issues pending before the Court, this case should be stayed 

until such time as the parties have the opportunity to file their objections, if any, to the Report and 

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Recommendation [as to the Motion for Summary Judgment] and any responses and replies 

thereto.” [Dkt. 146].

3. Given the stay instituted by the Court in Dkt. 146, the instant Motion may be moot. 

However, in an abundance of caution, State Farm now seeks leave and respectfully requests a oneweek extension of time until March 31, 2022 to file anyReply in further support of its Objections

to or Appeal of the Magistrate’s ruling Class Certification and State Farm’s Motion to Exclude 

Plaintiff’s expert. The parties conferred, and Plaintiff’s counsel does not oppose this request. 

4. State Farm seeks this extension given the complexity and breadth of issues before 

the Court, as well as its need to comply with numerous deadlines in other cost of insurance cases 

pending nationally against State Farm regarding the same policy form at issue here. 

5. For these reasons, and for good cause shown, State Farm respectfully requests the 

Court grant this unopposed Motion for Leave and allow an extension of time until March 31, 2022 

for State Farm to file any Reply in further support of its Objections or Appeal to the Magistrate’s 

Report and Recommendations and Order [Dkt. 137].

Respectfully Submitted,

/s/ Susan E. Egeland

Wayne B. Mason 

ATTORNEY-IN-CHARGE

Texas Bar No. 13158950

wayne.mason@faegredrinker.com

Susan E. Egeland

Texas Bar No. 24040854

susan.egeland@faegredrinker.com

FAEGRE DRINKER BIDDLE & REATH LLP

1717 Main Street, Suite 5400

Dallas, Texas 75201

Phone: (469) 357-2500

Fax: (469) 327-0860

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Shaunda A. Patterson-Strachan 

(Admitted pro hac vice)

shaunda.pattersonstrachan@faegredrinker.com

FAEGRE DRINKER BIDDLE & REATH LLP

1500 K Street NW, Suite 1100

Washington, D.C. 20005

Phone: (202) 842-8800

Fax: (202) 842-8465

ATTORNEYS FOR DEFENDANT

STATE FARM LIFE INSURANCE COMPANY

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing document has been served 

on all counsel of record in accordance with the Federal Rules of Civil Procedure on March 22,

2022.

/s/ Susan E. Egeland

SUSAN E. EGELAND

CERTIFICATE OF CONFERENCE

I hereby certify that on March 22, 2022, I conferred via email with Plaintiff’s counsel 

regarding the substance of this Motion. Plaintiff does not oppose the relief requested as to the 

extension of time.

/s/ Susan E. Egeland

SUSAN E. EGELAND

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