`
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`
`Plaintiff,
`
`v.
`
`
`T-MOBILE USA, INC. and T-MOBILE US,
`INC.,
`
`
`Defendants.
`
`
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`§
`
`§
`Case No. 2:21-cv-00072-JRG
`§
`(LEAD CASE)
`§
`
`JURY TRIAL DEMANDED
`§
`§
`
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`
`JOINT MOTION TO STAY ALL DEADLINES AND NOTICE OF SETTLEMENT
`
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`
`Plaintiff,
`
`v.
`
`
`UBER TECHNOLOGIES, INC., d/b/a
`UBER,
`
`
`Defendant.
`
`
`Case No. 2:21-cv-00026-JRG
`(MEMBER CASE)
`
`JURY TRIAL DEMANDED
`
`
`
`Pursuant to the Federal Rules of Civil Procedure, Plaintiff AGIS Software Development
`
`LLC (“AGIS”) and Defendant Uber Technologies, Inc., d/b/a Uber (“Uber”) (collectively, the
`
`“Parties”), hereby file this Joint Motion to Stay All Deadlines and Notice of Settlement.
`
`All matters in controversy between the Parties have been settled in principle. The Parties
`
`respectfully request a stay of all deadlines for thirty (30) days while the Parties finalize a settlement
`
`agreement and file dismissal documents with the Court.
`
`WHEREFORE, the Parties respectfully request that the Court enter the proposed order
`
`submitted with this motion as set forth above.
`
`
`
`
`
`
`
`Case 2:21-cv-00072-JRG-RSP Document 354 Filed 01/25/22 Page 2 of 4 PageID #: 23149
`
`Dated: January 25, 2022
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`/s/ Alfred R. Fabricanat
`Alfred R. Fabricant
`NY Bar No. 2219392
`Email: ffabricant@fabricantllp.com
`Peter Lambrianakos
`NY Bar No. 2894392
`Email: plambrianakos@fabricantllp.com
`Vincent J. Rubino, III
`NY Bar No. 4557435
`Email: vrubino@fabricantllp.com
`FABRICANT LLP
`411 Theodore Fremd Ave., Suite 206 South
`Rye, New York 10580
`Telephone: (212) 257-5797
`Facsimile: (212) 257-5796
`
`Samuel F. Baxter
`Texas State Bar No. 01938000
`Email: sbaxter@mckoolsmith.com
`Jennifer L. Truelove
`Texas State Bar No. 24012906
`Email: jtruelove@mckoolsmith.com
`MCKOOL SMITH, P.C.
`104 E. Houston Street, Suite 300
`Marshall, Texas 75670
`Telephone: (903) 923-9000
`Facsimile: (903) 923-9099
`
`ATTORNEYS FOR PLAINTIFF AGIS
`SOFTWARE DEVELOPMENT LLC
`
`
` /s/ Melissa R. Smith (with permission)
`Mark N. Reiter
`Texas State Bar No. 16759900
`Email: mreiter@gibsondunn.com
`Robert A. Vincent
`Texas State Bar No. 24056474
`Email: rvincent@gibsondunn.com
`Nathan R. Curtis
`Texas State Bar No. 24078390
`Email: ncurtis@gibsondunn.com
`Ashbey N. Morgan
`Texas State Bar No. 24106339
`
`2
`
`
`
`Case 2:21-cv-00072-JRG-RSP Document 354 Filed 01/25/22 Page 3 of 4 PageID #: 23150
`
`anmorgan@gibsondunn.com
`GIBSON, DUNN & CRUTCHER LLP
`2001 Ross Avenue, Suite 2100
`Dallas, TX 75201-6912
`Telephone: 214.698.3360
`Facsimile: 214.571.2907
`
`Melissa R. Smith
`Texas State Bar No. 24001351
`GILLAM & SMITH, LLP
`303 South Washington Avenue
`Marshall, Texas 75670
`Telephone: 90.934.8450
`Facsimile: 903.934.9257
`Email: melissa@gillamsmithlaw.com
`
`ATTORNEYS FOR DEFENDANT UBER
`TECHNOLOGIES, INC., D/B/A UBER
`
`
`
`
`3
`
`
`
`Case 2:21-cv-00072-JRG-RSP Document 354 Filed 01/25/22 Page 4 of 4 PageID #: 23151
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that on January 25, 2022, all counsel of record who are
`
`deemed to have consented to electronic service are being served with a copy of this document via
`
`the Court's CM/ECF system per Local Rule CV-5(a)(3).
`
`
`
`
`
`
`
`/s/ Alfred R. Fabricant
` Alfred R. Fabricant
`
`
`
`CERTIFICATE OF CONFERENCE
`
`The undersigned hereby certifies that all counsel of record have met and conferred in
`
`accordance with Local Rule CV-7(h) and this Joint Motion is unopposed.
`
`
`
`/s/ Alfred R. Fabricant
` Alfred R. Fabricant
`
`
`
`
`
`
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