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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
SHERMAN DIVISION
UNITED STATES OF AMERICA
ex rel. PAUL PIETSCHNER,
Plaintiff,
v.
KATHRYN PETRALIA;
ROBERT FROHWEIN; and
SPENCER ROBINSON,
Defendants.
Civil Action No.: 4:21-cv-110-SDJ
DEFENDANT SPENCER ROBINSON’S UNOPPOSED MOTION FOR LEAVE
OF COURT TO FILE REPLY BRIEF IN EXCESS OF PAGE LIMITATION
Defendant Spencer Robinson respectfully moves for leave to file an individual reply brief
exceeding the page limit set forth in the Court’s Order Permitting Consolidated Briefing and
Extending Page Limits and Deadlines (Dkt. #64).
Under that Order, each Defendant is permitted to file a separate reply in support of their
individual motion to dismiss, not to exceed 10 pages. Mr. Robinson now seeks leave to extend this
limitation to 18 pages. Good cause exists for the requested extension. The government filed a 106-
page consolidated opposition to Defendants’ motions to dismiss (Dkt. #72), which addresses
arguments raised in Mr. Robinson’s individual Motion to Dismiss more than forty times. Mr.
Robinson submits that a modest increase in the page limit is necessary to adequately respond to
the government’s extensive arguments directed specifically at his motion and to ensure the Court
has a complete record upon which to decide the issues.
The Government does not oppose this request based on understandings that this will be the
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only request for additional pages on the defense replies due tomorrow, and that Defendant
Robinson will not oppose a reciprocal extension for the Government to address issues in Mr.
Robinson’s reply brief.
Accordingly, Mr. Robinson requests that the Court grant leave to file a reply brief not
exceeding 18 pages.
Dated: May 8, 2025
Respectfully submitted,
/s/ Henry W. Asbill
Henry W. Asbill (admitted Pro Hac Vice)
Christopher B. Mead (admitted Pro Hac Vice)
Lisa H. Schertler (admitted Pro Hac Vice)
Paola Pinto (admitted Pro Hac Vice)
Schertler Onorato Mead & Sears, LLP
555 13th Street, N.W. | Suite 500 West
Washington, DC 20004
hasbill@schertlerlaw.com
cmead@schertlerlaw.com
lschertler@schertlerlaw.com
ppinto@schertlerlaw.com
Phone: (202) 628-4199
Fax: (202) 628-4177
Counsel for Defendant Spencer Robinson
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CERTIFICATE OF SERVICE
I hereby certify that on May 8, 2025, I caused the foregoing to be filed electronically with
the Clerk of the Court using the CM/ECF system, which will send notification of such filing to
counsel of record.
Dated: May 8, 2025
Respectfully Submitted,
/s/ Henry W. Asbill
Henry W. Asbill (admitted Pro Hac Vice)
Schertler Onorato Mead & Sears, LLP
555 13th Street, N.W. | Suite 500 West
Washington, DC 20004
hasbill@schertlerlaw.com
Phone: (202) 628-4199
Fax: (202) 628-4177
Counsel for Defendant Spencer Robinson
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CERTIFICATE OF CONFERENCE
Pursuant to Local Rule CV-7(i), counsel for Mr. Robinson certifies compliance with the
meet and confer requirement in Local Rule CV-7(h). Counsel for Mr. Robinson met and conferred
in good faith with counsel for the Government, counsel for Relator, counsel for Kathryn Petralia,
and counsel for Robert Frohwein via email on May 7, 2025. Counsel for Mr. Robinson met and
conferred in good faith with counsel for the Government again on May 8, 2025, via telephone and
email. The Government, counsel for Kathryn Petralia, and counsel for Robert Frohwein do not
oppose the present Motion. As of the filing of this Motion, counsel for Relator has not responded
to counsel for Mr. Robinson.
/s/ Henry W. Asbill
Henry W. Asbill
Counsel for Spencer Robinson
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