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DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT PAGE 1

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

SAN ANTONIO DIVISION

ANNA GONZALEZ and RONALD K. 

PAGE, on behalf of themselves and all 

others similarly situated,

Plaintiffs,

v.

STATE FARM LIFE INSURANCE 

COMPANY,

Defendant.

Civil Action No. 5:20-cv-00617

DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME 

TO RESPOND TO PLAINTIFFS’ FIRST AMENDED CONSOLIDATED 

CLASS ACTION COMPLAINT AND DEMAND FOR JURY TRIAL

Defendant State Farm Life Insurance Company respectfully requests an extension of time 

of 7 days to respond to Plaintiffs’ First Amended Consolidated Class Action Complaint and 

Demand for Jury Trial [Dkt. 72]. Counsel for Defendant conferred with Plaintiffs’ counsel

who is unopposed to the relief requested herein.

1. On March 1, 2021, Plaintiffs filed their Unopposed Motion for Leave to File First

Amended Consolidated Class Action Complaint. [Dkt. 71]. The Court docketed Plaintiffs’ First

Amended Consolidated Class Action Complaint on March 2, 2021. [Dkt. 72].

2. During a phone conference on February 24, 2021, counsel for State Farm advised 

Plaintiffs’ counsel they did not oppose Plaintiffs’ Motion for Leave, but that Defendant would 

request an additional 7 days to respond to Plaintiffs’ First Amended Consolidated Class Action 

Complaint as a professional courtesy.

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DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT PAGE 2

3. Plaintiffs’ counsel advised they do not oppose Defendant’s request to enlarge the 

time for filing a response by 7 days, which would make the new deadline March 23, 2021.

4. The relief requested is for good cause and will not result in undue delay in the 

administration of this case. Plaintiffs’ First Amended Consolidated Class Action Complaint

raises complex issues of law. An enlargement of time for filing Defendant’s response is 

necessary to allow Defendant and its counsel time to review and respond to Plaintiffs’ new

allegations.

5. For these reasons, Defendant respectfully moves that the Court extend the time 

for responding to Plaintiffs’ First Amended Consolidated Class Action Complaint by 7 days, 

making the deadline March 23, 2021.

Dated: March 3, 2021 Respectfully submitted,

/s/ Susan E. Egeland

Wayne B. Mason 

ATTORNEY-IN-CHARGE

Southern District Bar No. 8694 

Texas Bar No. 13158950

wayne.mason@faegredrinker.com

Susan E. Egeland

Southern District Bar No. 1804016

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

Shaunda A. Patterson-Strachan 

(Admitted pro hac vice)

shaunda.pattersonstrachan@faegredrinker.com

Waldemar J. Pflepsen Jr. 

(Admitted pro hac vice)

waldemar.pflepsen@faegredrinker.com

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DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT PAGE 3

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

I certify that on March 3, 2021, a true and correct copy of the above and foregoing 

document was electronically filed with the Clerk of Court using the CM/ECF system, which will 

send notification of such filing to all counsel of record who are deemed to have consented to 

electronic service.

/s/ Susan E. Egeland

SUSAN E. EGELAND

CERTIFICATE OF CONFERENCE

This is to certify that on February 24, 2021, the undersigned conferred with Plaintiffs’ 

counsel via phone and email regarding the substance of this Motion. Plaintiffs’ counsel 

consented to Defendant’s request to enlarge the time for filing its response to Plaintiffs’ First 

Amended Consolidated Class Action Complaint by 7 days.

/s/ Susan E. Egeland

SUSAN E. EGELAND

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