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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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`Case No. 2:22-md-03034-TGB
`HON. TERRENCE G. BERG
`JURY TRIAL DEMANDED
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`UNOPPOSED MOTION FOR ENTRY OF STIPULATED
`SUPPLEMENTAL PROTECTIVE ORDER
`Neo Wireless LLC hereby files this Unopposed Motion for Entry of the
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`Stipulated Supplemental Protective Order Regarding Non-Party Mercedes
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`(“Supplemental Protective Order”). Mercedes has requested, and Neo does not
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`oppose, that the Court enter this Supplemental Protective Order to govern
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`confidential information of non-parties Mercedes-Benz USA, LLC and Mercedes-
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`Benz AG (together “Mercedes”) that has been produced in this action. Thus, per
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`Mercedes’s request, Neo moves to enter the Supplemental Protective Order
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`attached hereto as Exhibit A. Mercedes has notified Neo that the Defendants in this
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`matter do not oppose entry of the Supplemental Protective Order.
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`Therefore, Neo Wireless respectfully requests that the Court enter the
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`proposed Stipulated Supplemental Protective Order as attached hereto.
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`1
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`Case 2:22-md-03034-TGB ECF No. 284, PageID.30974 Filed 08/28/24 Page 2 of 3
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`DATED: August 28, 2024
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`Respectfully submitted,
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`/s/ Jason D. Cassady
`Jason D. Cassady
`Texas Bar No. 24045625
`Email: jcassady@caldwellcc.com
`Christopher S. Stewart
`Texas Bar No. 24079399
`Email: cstewart@caldwellcc.com
`Daniel R. Pearson
`Texas Bar No. 24070398
`Email: dpearson@caldwellcc.com
`Hamad M. Hamad
`Texas Bar No. 24061268
`Email: hhamad@caldwellcc.com
`Bailey A. Blaies
`Texas Bar No. 24109297
`Email: bblaies@caldwellcc.com
`Bjorn. A. Blomquist
`Texas Bar No. 24125125
`Email: bblomquist@caldwellcc.com
`James F. Smith
`Texas Bar No. 24129800
`Email: jsmith@caldwellcc.com
`James Yang
`California Bar No. 329979
`Email: jyang@caldwellcc.com
`Alexander J. Gras
`Texas Bar No. 24125252
`Email: agras@caldwellcc.com
`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)
`Email: jcquadrozzi@varnumlaw.com
`VARNUM LLP
`480 Pierce Street, Suite 300
`Birmingham, Michigan 48009
`Telephone:
`(248) 567-7800
`Facsimile:
`(214) 567-7423
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`ATTORNEYS FOR PLAINTIFF
`NEO WIRELESS LLC
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`2
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`Case 2:22-md-03034-TGB ECF No. 284, PageID.30975 Filed 08/28/24 Page 3 of 3
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that on August 28, 2024, the foregoing document
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`was filed electronically with the Clerk of Court using the CM/ECF system, which
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`will send notification of such filing to all attorneys of record.
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`/s/ Christopher S. Stewart
`Christpher S. Stewart
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`CERTIFICATE OF CONFERENCE
`The undersigned hereby certifies that counsel has complied with the meet
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`and confer requirements of Federal and Local Rules. Counsel for both parties
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`discussed the issues presented here on August 28, 2024. Counsel for Defendants
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`have indicated that they are not opposed to the relief sought herein.
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`/s/Christopher S. Stewart
`Christopher S. Stewart
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