`Case 2:17-cv-00517-JRG Document 64-14 Filed 05/21/18 Page 1 of 4 PageID #: 890
`
`
`
`
`EXHIBIT 13
`EXHIBIT 13
`
`
`
`
`
`
`
`
`Case 2:17-cv-00517-JRG Document 64-14 Filed 05/21/18 Page 2 of 4 PageID #: 891
`
`D'Aquila, Danielle
`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Moore, Steve <steve.moore@pillsburylaw.com>
`Wednesday, May 02, 2018 10:51 AM
`D'Aquila, Danielle; Nash, Brian C.; Ko, Jack; Wisnia, Howard N.
`AGIS-Lit
`RE: AGIS Software Development, LLC v. ZTE Corp., No. 2:17-cv-517 (E.D. Tex. 2017)
`
`Follow Up Flag:
`Flag Status:
`
`Follow up
`Flagged
`
`Danielle
`
`
`We don’t represent them in this matter. I would invite you to reach out to the team that does. As you know, Finnegan
`Henderson is the firm responsible for the representation of the ZTE entities in the AGIS Software case. We are not
`authorized to take any action on behalf of any party in this case.
`
`
`Best regards,
`
`
`Steve
`
`
`Steve Moore, JD., Ph.D. | Partner
`Pillsbury Winthrop Shaw Pittman LLP
`501 West Broadway, Suite 1100 | San Diego, CA 92101-3575
`t 619.544.3112 | f 619.236.1995 | m +1.760.807.8651
`Suite 2404, 24/F Kinwick Centre 32 Hollywood Road | Central Hong Kong
`t +852.3959.7500 | m +86.138.1669.0401
`steve.moore@pillsburylaw.com | website bio
`
`
`From: D'Aquila, Danielle <DD'Aquila@brownrudnick.com>
`Sent: Wednesday, May 2, 2018 7:16 AM
`To: Moore, Steve <steve.moore@pillsburylaw.com>; Nash, Brian C. <brian.nash@pillsburylaw.com>; Ko, Jack
`<jack.ko@pillsburylaw.com>; Wisnia, Howard N. <howard.wisnia@pillsburylaw.com>
`Cc: AGIS-Lit <agislit@brownrudnick.com>
`Subject: RE: AGIS Software Development, LLC v. ZTE Corp., No. 2:17-cv-517 (E.D. Tex. 2017)
`
`
`
`
`Counsel,
`
`I am following up regarding my below email. Let me know if you are available for a call this week to discuss whether
`your client, ZTE Corporation, authorizes you to accept service of the Summons and Complaint and the Amended
`Complaint in the above-referenced action.
`
`
`Regards,
`Danielle
`
`
`
`
`1
`
`
`
`Case 2:17-cv-00517-JRG Document 64-14 Filed 05/21/18 Page 3 of 4 PageID #: 892
`
`
`
`
`
`
`Danielle A. D'Aquila
`Counselor at Law
`
`Brown Rudnick LLP
`Seven Times Square
`New York, NY 10036
`T: 212-209-4985
`F: 212-938-2885
`ddaquila@brownrudnick.com
`www.brownrudnick.com
`Please consider the environment before printing this e-mail
`
`
`
`
`
`From: D'Aquila, Danielle
`Sent: Saturday, April 21, 2018 9:42 AM
`To: steve.moore@pillsburylaw.com; brian.nash@pillsburylaw.com; jack.ko@pillsburylaw.com;
`howard.wisnia@pillsburylaw.com
`Cc: AGIS-Lit
`Subject: AGIS Software Development, LLC v. ZTE Corp., No. 2:17-cv-517 (E.D. Tex. 2017)
`
`
`Counsel,
`
`
`We represent Plaintiff AGIS Software Development, LLC ("AGIS") in an action against ZTE Corporation, AGIS
`Software Development, LLC v. ZTE Corp., et al., No. 2:17-cv-517 (E.D. Tex. June 21, 2017) ("AGIS v. ZTE"). We
`are reaching out to you because, based on publicly available information, it is our understanding that you
`currently represent ZTE Corporation. We initiated service of process of the Summons and Complaint and
`corresponding exhibits (attached hereto) in the AGIS v. ZTE action through the Hague Convention over eight
`months ago. While the typical time period for receiving proof of service from the Central Authority has expired, it
`is our understanding that ZTE Corporation still has not been served and that service may take another five
`months. Approximately four months after initiating the lawsuit, AGIS amended its complaint, which is also
`attached.
`
`
`As U.S. counsel to ZTE Corporation, please let us know whether ZTE Corporation would be willing to waive
`formal service of the Summons and Complaint and Amended Complaint through the Hague Convention, and
`accept service of process of these documents via email through counsel at your firm. We are generally available
`next week to discuss AGIS's request.
`
`Regards,
`Danielle D'Aquila
`
`
`
`
`
`
`
`
`
`Danielle A. D'Aquila
`Counselor at Law
`
`Brown Rudnick LLP
`Seven Times Square
`New York, NY 10036
`T: 212-209-4985
`F: 212-938-2885
`ddaquila@brownrudnick.com
`www.brownrudnick.com
`
`
`
`2
`
`
`
`Case 2:17-cv-00517-JRG Document 64-14 Filed 05/21/18 Page 4 of 4 PageID #: 893
`
`Please consider the environment before printing this e-mail
`
`
`
`
`
`***********************************************************************************
`
`The information contained in this electronic message may be legally privileged and confidential under applicable law, and is intended only for the use of
`the individual or entity named above. If the recipient of this message is not the above-named intended recipient, you are hereby notified that any
`dissemination, copy or disclosure of this communication is strictly prohibited. If you have received this communication in error, please notify Brown
`Rudnick LLP, (617) 856-8200 (if dialing from outside the US, 001-(617)-856-8200) and purge the communication immediately without making any copy
`or distribution.
`
`***********************************************************************************
`
`
`
`
`The contents of this message, together with any attachments, are intended only for the use of the individual or
`entity to which they are addressed and may contain information that is legally privileged, confidential and
`exempt from disclosure. If you are not the intended recipient, you are hereby notified that any dissemination,
`distribution, or copying of this message, or any attachment, is strictly prohibited. If you have received this
`message in error, please notify the original sender or the Pillsbury Winthrop Shaw Pittman Help Desk at Tel:
`800-477-0770, Option 1, immediately by telephone or by return E-mail and delete this message, along with any
`attachments, from your computer. Thank you.
`
`
`
`
`
`
`
`3
`
`