`
`No. 24-20346
`In the United States Court of Appeals
`for the Fifth Circuit
`
`
`
`TAMBRIA LEE,
`Appellant,
`v.
`SOUTHWEST AIRLINES, CO.,
`Appellee.
`
`
`
`On Appeal from the United States District Court for the Southern District of Texas,
`Houston Division, (Civil Action No. 4:21-cv-01901)
`
`APPELLEE’S REQUEST FOR EXTENSION OF TIME TO RESPOND TO
`APPELLANT’S MOTION TO COMPEL
`
`
`
`
`
`
`
`
`
`
`
`Jonathan G. Rector
`Texas State Bar No. 24090347
`Federal I.D. No. 2376006
`LITTLER MENDELSON, P.C.
`2001 Ross Avenue, Suite 1500
`Dallas, TX 75201.2931
`214.880.8100
`214.880.0181 (Fax)
`jrector@littler.com
`
`ATTORNEY OF RECORD FOR
`DEFENDANT/APPELLEE
`SOUTHWEST AIRLINES, CO.
`
`
`
`
`
`Case: 24-20346 Document: 43 Page: 2 Date Filed: 12/26/2024
`
`TO THE HONORABLE FIFTH CIRCUIT COURT OF APPEALS:
`
`NOW COMES, Appellee Southwest Airlines Co.
`
`(“Appellee” or
`
`“Southwest”) requesting an extension of time to respond to Appellant Tambria
`
`Lee’s (“Appellant” or “Lee”) Motion to Compel (“Motion”). In support of this
`
`request for extension, Appellee shows the Court as follows:
`
`On December 18, 2024, Lee filed the procedurally improper Motion,1
`
`requesting the Court to compel the production of certain documents and
`
`information.2 See Dkt. 36. Under Federal Rule of Appellate Procedure 27(a)(3)(A),
`
`Southwest’s deadline to respond to the Motion is on Monday, December 30, 2024.
`
`Due to the holidays occurring during the period of time to respond and previously
`
`scheduled vacations, Southwest respectfully requests a fourteen-day extension, or
`
`until January 13, 2025, to prepare a response to Lee’s Motion, to the extent the
`
`Court does not intend to deny the Motion prior to Southwest submitting an answer.
`
`For the foregoing reasons, Appellee Southwest Airlines Co. respectfully
`
`requests that the Court grant its request for a fourteen-day extension to prepare a
`
`
`1 On several occasions, counsel for Southwest explained to Lee that motions to
`compel are not procedurally proper under the Federal Rules of Appellate
`Procedure.
`2 Of note, this Motion was filed less than two weeks before Lee’s opening brief is
`due on December 31, 2024. Southwest anticipates that Lee will continue her
`dilatory tactics by requesting yet another extension to file her opening brief and use
`the Motion as a basis to support her request and continue to prejudice Southwest.
`2
`
`
`
`
`
`Case: 24-20346 Document: 43 Page: 3 Date Filed: 12/26/2024
`
`response to Lee’s Motion, and such other and further relief to which it is justly
`
`entitled.
`
`
`
`DATE: December 26, 2024
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/s/ Jonathan G. Rector
`Jonathan G. Rector
`Texas State Bar No. 24090347
`Federal I.D. No. 2376006
`LITTLER MENDELSON, P.C.
`2001 Ross Avenue, Suite 1500
`Dallas, TX 75201.2931
`214.880.8100
`214.880.0181 (Fax)
`jrector@littler.com
`ATTORNEY OF RECORD FOR
`DEFENDANT/APPELLEE
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on the 26th day of December, 2024, I electronically
`
`filed the foregoing with the Clerk for the U.S. Court of Appeals for the Fifth
`Circuit using the CM/ECF system, and was also served on Plaintiff/Appellant via
`U.S. Mail and email as follows:
`
`
`Tambria Lee
`5868 Westheimer Rd, #164
`Houston, Texas 77057
`TambriaELee@gmail.com
`
`
`
`
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`
`
`
`
` 4922-1314-2794.1 / 103917-1016
`
`
`
`
`
`
`
`
`/s/ Jonathan G. Rector
`Jonathan G. Rector
`
`
`
`3
`
`
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