Defendant Spencer Robinson’s Corrected Unopposed Motion

Summary

Defendant Spencer Robinson files a corrected unopposed motion for leave to file an individual reply brief exceeding the page limit set in the Court's Order Permitting Consolidated Briefing and Extending Page Limits and Deadlines, seeking to extend that limit to 11 pages. The motion states that the Government filed a consolidated opposition to Defendants' motions to dismiss that addresses arguments raised in Mr. Robinson's individual Motion to Dismiss more than forty times. It says Mr. Robinson previously sought an 18-page limit and is revising the request to 11 pages. The certificate of conference says the Government and counsel for Kathryn Petralia and Robert Frohwein did not oppose, and counsel for Relator had not responded as of filing.

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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  CORRECTED 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 10-page limit set forth in the Court’s Order Permitting Consolidated Briefing and
Extending Page Limits and Deadlines (Dkt. 64).
Mr. Robinson now seeks leave to extend this limitation to 11 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.
Mr. Robinson previously filed a motion for leave seeking to extend the limitation to 18
pages (Dkt. 88). The Government did not oppose this request based on understandings that this
Case 4:21-cv-00110-SDJ     Document 89     Filed 05/09/25     Page 1 of 4 PageID #:  917

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will be the only request for additional pages on the defense replies due today, 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 11 pages.
Dated: May 9, 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

Case 4:21-cv-00110-SDJ     Document 89     Filed 05/09/25     Page 2 of 4 PageID #:  918

3

CERTIFICATE OF SERVICE
I hereby certify that on May 9, 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 9, 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

Case 4:21-cv-00110-SDJ     Document 89     Filed 05/09/25     Page 3 of 4 PageID #:  919

4

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 regarding his 18-page extension (DKT. #88) 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 did not oppose the Motion.  Mr. Robinson is revising
his request to seek only 11 pages.  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
Case 4:21-cv-00110-SDJ     Document 89     Filed 05/09/25     Page 4 of 4 PageID #:  920

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