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IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

AUSTIN DIVISION 

BRYNNE SOUKUP, ) 

Plaintiff, ) 

) Civil Action No. 1:20-cv-648-RP 

v. ) 

) 

FRONTIER AIRLINES, INC. and ) 

FLIGHT SERVICES & SYSTEMS, LLC, ) 

Defendants. ) 

JOINT MOTION TO CONTINUE THE PARTIES’ EXPERT REPORT DEADLINES 

NOW INTO COURT, come Plaintiff, Brynne Soukup (“Plaintiff”), and Defendant, Flight 

Services & Systems, LLC (“Defendant” or “FSS”), who file this Joint Motion to Continue the 

Parties’ Expert Report Deadlines in the above-captioned matter and respectfully request a 60-day 

extension for each party to serve their expert reports – for the reasons more fully explained herein. 

1. On July 21, 2020, Plaintiff filed an amended complaint alleging workplace discrimination, 

harassment, and retaliation against co-defendants, FSS and Frontier Airlines, Inc. See

Amended Complaint, Rec. Doc. 7. 

2. In response, Frontier Airlines, Inc. filed a Motion to Dismiss, Rec. Doc. 10, on August 4, 

2020, and FSS filed its own Motion to Dismiss, Rec. Doc. 19, on October 7, 2020. 

3. While FSS’s and Frontier Airlines, Inc.’s Motions to Dismiss were pending, the Parties 

agreed to delay significant discovery until the motions were ruled upon – so that the Parties 

could focus their discovery efforts on the surviving claims and/or parties. 

4. On February 9, 2021, this Court granted Frontier Airlines, Inc.’s Motion to Dismiss in 

whole and granted FSS’s Motion to Dismiss in part, dismissing Plaintiff’s harassment 

claims against FSS. See Order, Rec. Doc. 33. 

Case 1:20-cv-00648-RP Document 34 Filed 03/23/21 Page 1 of 3
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5. Since then, Plaintiff and FSS have conducted and continue to conduct discovery. 

6. Under the Scheduling Order, Plaintiff’s deadline to serve expert reports is March 12, 2021, 

and FSS’s deadline to serve expert reports is April 12, 2021. See Rec. Doc. 28. 

7. Plaintiff and FSS respectfully request that both Parties’ deadlines to serve expert reports 

be extended 60-days in order to provide the Parties with additional time to conduct 

discovery on Plaintiff’s surviving claims. 

8. Specifically, Plaintiff respectfully requests a 60-day extension, or until May 11, 2021, to 

serve her expert reports, and FSS respectfully requests a 60-day extension, or until June 11, 

2021, to serve its expert reports. 

9. The discovery deadline is this case is August 20, 2021, and this case is currently set for a 

jury trial beginning December 13, 2021. 

10. The requested 60-day extension of the Parties’ respective expert report deadlines will not 

affect the trial date or other pre-trial deadlines. 

11. Plaintiff and FSS respectfully represent that they are not seeking this extension for any 

improper purpose and that this is the first request for an extension of any pre-trial deadline 

by either party. 

WHEREFORE, Plaintiff, Brynne Soukup, and Defendant, Flight Services & Systems, 

LLC, respectfully request that the Court grant this Joint Motion to Continue the Parties’ Expert 

Report Deadlines in the above-captioned matter, extending Plaintiff’s deadline to serve expert 

reports until May 11, 2021, and extending FSS’s deadline to serve expert reports until June 11, 

2021. 

Case 1:20-cv-00648-RP Document 34 Filed 03/23/21 Page 2 of 3
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Respectfully Submitted: 

/s/ Trenton Lacy 

Daniel B. Ross 

State Bar No. 00789810 

Trenton Lacy 

State Bar No. 24106176 

ROSS • SCALISE LAW GROUP 

1104 San Antonio Street 

Austin, Texas 78701 

Telephone: (512) 474-7677 

Facsimile: (512) 474-5306 

dan@rosslawgroup.com 

trenton@rosslawgroup.com 

-andCHAFFE McCALL, LLP 

/s/ Sarah V. Myers 

Sarah Voorhies Myers (pro hac vice) 

Amy L. McIntire (pro hac vice) 

2300 Energy Centre, 1100 Poydras Street 

New Orleans, LA 70163 

T: (504) 585-7000 

F: (504) 544-6092 

E: myers@chaffe.com 

E: mcintire@chaffe.com 

H. Michael Bush 

Texas Bar No.24054296 

2300 Energy Centre, 1100 Poydras Street 

New Orleans, LA 70163 

T: (504) 585-7000 

F: (504) 544-6042 

E: bush@chaffe.com 

Attorneys for Defendant, 

Flight Services & Systems, LLC

Case 1:20-cv-00648-RP Document 34 Filed 03/23/21 Page 3 of 3