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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
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`IN RE NEO WIRELESS, LLC
`PATENT LITIG.
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`NEO WIRELESS, LLC,
`Plaintiff,
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`v.
`MERCEDES-BENZ USA, LLC,
`Defendant.
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`2:22-MD-03034-TGB
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`HON. TERRENCE G. BERG
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`2:22-CV-11769-TGB
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`HON. TERRENCE G. BERG
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`JOINT NOTICE OF SETTLEMENT AND REQUEST FOR STAY
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`Plaintiff Neo Wireless, LLC (“Neo”) and Defendant Mercedes-Benz USA,
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`LLC (“MBUSA”) hereby notify the Court that they have reached a definitive
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`agreement regarding settlement.
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`The parties respectfully request that all proceedings in the member case Neo
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`Wireless, LLC v. Mercedes-Benz USA, LLC, No. 2:22-cv-11769-TGB be stayed for
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`30 days from today (through July 6, 2023) while the final details of the settlement,
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`including payment, are completed. As soon as the settlement is fully concluded, the
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`parties will jointly file a motion to dismiss the case as to MBUSA. For avoidance
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`of doubt, both this request for a stay and the pending settlement agreement pertain
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`1
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`Case 2:22-md-03034-TGB ECF No. 147, PageID.10670 Filed 06/06/23 Page 2 of 3
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`solely to the dispute between Neo and MBUSA, and all other actions in this MDL
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`are unaffected by the same.
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`DATED: June 6, 2023
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`Respectfully submitted,
`/s/ Christopher S. Stewart
`Jason D. Cassady
`Texas State Bar No. 24045625
`Email: jcassady@caldwellcc.com
`Christopher S. Stewart
`Texas State Bar No. 24079399
`Email: cstewart@caldwellcc.com
`CALDWELL CASSADY CURRY P.C.
`2121 N. Pearl St., Suite 1200
`Dallas, Texas 75201
`Telephone: (214) 888-4848
`Facsimile: (214) 888-4849
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`Jaye Quadrozzi (P71646)
`YOUNG, GARCIA & QUADROZZI, PC
`2775 Stansbury Blvd., Suite 125
`Farmington Hills, MI 48334
`Telephone: (248) 353-8620
`Email: quadrozzi@youngpc.com
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`ATTORNEYS FOR PLAINTIFF
`NEO WIRELESS, LLC
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`/s/ Celine J. Crowson
`Celine J. Crowson
`Joseph J. Raffetto
`Damon M. Lewis
`Nicholas W. Rotz
`Hogan Lovells US LLP
`555 Thirteenth St, NW
`Washington, DC 20004
`Telephone: (202) 637-5703
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`2
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`Case 2:22-md-03034-TGB ECF No. 147, PageID.10671 Filed 06/06/23 Page 3 of 3
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`Facsimile: (202) 637-5910
`Email: celine.crowson@hoganlovells.com
`Email: joseph.raffetto@hoganlovells.com
`Email: damon.lewis@hoganlovells.com
`Email: nicholas.rotz@hoganlovells.com
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`James A. Martone
`Dickinson Wright PLLC
`2600 W. Big Beaver Road, Ste. 300
`Troy, MI 48084-3312
`Tel: 248-433-7391
`Fax: 248-433-8284
`Email: Jmartone@dickinsonwright.com
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`ATTORNEYS FOR DEFENDANT
`MERCEDES-BENZ USA, LLC
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that on June 6, 2023, the foregoing document was
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`filed electronically with the Clerk of Court using the CM/ECF system, which will
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`send notification of such filing to all attorneys of record.
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`/s/ Christopher S. Stewart
`Christopher S. Stewart
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`3
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