`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
`
`
`IN RE NEO WIRELESS, LLC
`PATENT LITIG.
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`NEO WIRELESS, LLC v.
`VOLKSWAGEN GROUP OF
`AMERICA, INC., ET AL.
`
`§
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`2:22-MD-03034-TGB
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`HON. TERRENCE G. BERG
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`2:22-CV-11404-TGB
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`HON. TERRENCE G. BERG
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`JOINT MOTION FOR STAY PENDING SETTLEMENT
`Pursuant to Federal Rule of Civil Procedure 16(b)(4), Plaintiff Neo
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`Wireless, LCC and Defendants Volkswagen Group of America, Inc. and
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`Volkswagen Group of America Chattanooga Operations, LLC (“Volkswagen”)
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`hereby jointly request a one month stay of all obligations and deadlines set out in
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`the Court’s Scheduling Order (Dkt. 84), as to Volkswagen only.
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`Neo and Volkswagen have reached an agreement in principle to settle the
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`case and resolve their dispute, and expect to jointly move to dismiss the case in
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`short order. However, because of the holidays, the parties need additional time to
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`fully finalize a formal settlement agreement. Thus, the parties request a one month
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`stay to enable the parties to finalize the agreement, while avoiding burdening the
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`Court or the parties with unnecessary discovery practice in the meantime. As soon
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`Case 2:22-md-03034-TGB ECF No. 205, PageID.11796 Filed 12/15/23 Page 2 of 4
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`as the parties’ formal settlement is finalized, the parties will shortly thereafter file
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`a Joint Motion to Dismiss. If for some reason the parties cannot finalize the
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`agreement by January 15th, counsel for the parties will request a conference with
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`the Court and jointly propose an adjusted case schedule for Volkswagen only that
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`does not disrupt the deadlines for any other Defendant or the deadlines for
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`dispositive and Daubert motions currently set forth in the Scheduling Order.
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`Case 2:22-md-03034-TGB ECF No. 205, PageID.11797 Filed 12/15/23 Page 3 of 4
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`Date: December 15, 2023
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`/s/Daniel E. Yonan
`Susan M. McKeever
`Justin B. Weiner
`Bush Seyferth PLLC
`100 West Big Beaver Road
`Suite 400
`Troy, MI 48084
`(248) 822-7851
`mckeever@bsplaw.com
`weiner@bsplaw.com
`
`Daniel E. Yonan
`Deirdre M. Wells
`Ryan C. Richardson
`William H. Milliken
`Anna G. Phillips
`Sterne, Kessler, Goldstein & Fox P.L.L.C
`1100 New York Avenue NW
`Suite 600
`Washington, DC 20005
`(202) 371-2600
`dyonan@sternekessler.com
`dwells@sternekessler.com
`rrichardson@sternekessler.com
`wmilliken@sternekessler.com
`aphillips@sternekessler.com
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`Counsel for Defendants Volkswagen
`Group of America, Inc. and Volkswagen
`Group of America Chattanooga
`Operations, Inc.
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`Respectfully submitted,
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`/s/ Jason D. Cassady
`Jason D. Cassady
`Texas State Bar No. 24045625
`Email: jcassady@caldwellcc.com
`Christopher S. Stewart
`Texas State Bar No. 24079399
`Email: cstewart@caldwellcc.com
`Daniel R. Pearson
`Texas State Bar No. 24070398
`Email: dpearson@caldwellcc.com
`Bailey A. Blaies
`Texas State Bar No. 24109297
`Email: bblaies@caldwellcc.com
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`CALDWELL CASSADY CURRY
`P.C.
`2121 N. Pearl St., Suite 1200
`Dallas, Texas 75201
`Telephone: (214) 888-4848
`Facsimile: (214) 888-4849
`
`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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`Case 2:22-md-03034-TGB ECF No. 205, PageID.11798 Filed 12/15/23 Page 4 of 4
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`CERTIFICATE OF SERVICE
`The undersigned certifies that on December 15, 2023, the foregoing
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`document was filed electronically with the Clerk of Court using the CM/ECF
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`system, which will send notification of such filing to all attorneys of record.
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`/s/ Jason D. Cassady
`Jason D. Cassady
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