JOINT MOTION TO AMEND SCHEDULING ORDER PAGE 1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

 

MAURIE MOORE, §

§

Plaintiff, §

§

v. §

§

C.A. NO. 4:22-CV-201-Y

CARVANA, LLC, §

§

JURY TRIAL DEMANDED

Defendants. §

JOINT MOTION TO AMEND SCHEDULING ORDER

Pursuant to Federal Rule of Civil Procedure 16(b)(4), Plaintiff Maurie Moore 

(“Plaintiff”) and Defendant Carvana, LLC (“Defendant,” and together the “Parties”) jointly 

move the Court to amend the Scheduling Order entered by the Court on July 13, 2022 (Dkt 17) 

and extend the Parties’ deadlines as set forth in Exhibit A. 

Good cause exists to modify the Scheduling Order. The Parties have been engaged in 

ongoing, good faith efforts to conduct discovery, including exchanging written discovery, and 

attempting to schedule Plaintiff’s deposition and Defendant’s Rule 30(b)(6) corporate 

representative deposition ahead of the February 3, 2023 discovery deadline. However, due to 

witness availability issues and existing deadlines, including specifically Defendant’s counsel 

having an administrative hearing on January 18, 2023, and in separate matters, a trial set for 

January 9, 2023, and a trial set for January 23, 2023, it will be difficult for the Parties to 

complete discovery by the current February 3, 2023 discovery deadline.

The Parties agree that the amended schedule set forth in the attached proposed order is 

necessary to allow adequate time to engage in depositions, and to address any remaining issues 

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JOINT MOTION TO AMEND SCHEDULING ORDER PAGE 2

with discovery. Further, the Parties agree that the proposed amended schedule is necessary to 

allow the Parties to have all the necessary information about the case ahead of the formal 

settlement conference and adequate time to brief pretrial and dispositive motions before the case 

is set for trial. 

The Parties do not make this request for purposes of delay, but so that justice may be 

done. Accordingly, the Parties hereby jointly request that the Court enter the attached proposed 

order, attached hereto as Exhibit A. 

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JOINT MOTION TO AMEND SCHEDULING ORDER PAGE 3

Dated: December 16, 2022

By: /s/ Lisa Scheibly (with permission ERL)

Eric D. Rogers

Lisa Scheibly 

SPIELBERGER LAW GROUP

4890 W. Kennedy Blvd., Suite 950

Tampa, Florida 33609

Eric.rogers@spielbergerlawgroup.com

Lisa.Scheibly@spielbergerlawgroup.com

ATTORNEYS FOR PLAINTIFF MAURIE 

MOORE

Respectfully submitted,

By: /s/ Emily R. Linn

Kimberly R. Miers

Texas State Bar No. 24041482

kmiers@littler.com 

LITTLER MENDELSON

A Professional Corporation

2001 Ross Avenue

Suite 1500, Lock Box 116

Dallas, Texas 75201

214.880.8100 (Telephone)

214.880.0181 (Facsimile)

Emily R. Linn

Texas State Bar No. 24109478

LITTLER MENDELSON

A Professional Corporation

100 Congress Avenue, Suite 1400

Austin, Texas 78701

512.924.7087 (Telephone)

512.532.6501 (Facsimile)

ATTORNEYS FOR DEFENDANT

CARVANA, LLC

Case 4:22-cv-00201-Y Document 18 Filed 12/16/22 Page 3 of 4 PageID 71
JOINT MOTION TO AMEND SCHEDULING ORDER PAGE 4

CERTIFICATE OF SERVICE

I hereby certify that on December 16, 2022, the foregoing document was served upon all 

counsel of record via the court’s electronic filing system. 

/s/ Emily R. Linn

Emily R. Linn

Case 4:22-cv-00201-Y Document 18 Filed 12/16/22 Page 4 of 4 PageID 72