`
`
`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 EXTEND STAY OF ALL DEADLINES
`
`
`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
`
`
`
`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 Extend Stay
`
`of All Deadlines.
`
`All matters in controversy between the Parties have been settled in principle and, on
`
`January 25, 2022, the Parties jointly moved to stay all deadlines and provided notice of settlement
`
`to the Court (Dkt. 354). On January 26, 2022, this Court stayed the case for thirty (30) days until
`
`February 25, 2022 (Dkt. 356) while the Parties finalized a settlement agreement.
`
`The Parties respectfully and jointly request that the Court extend the stay of all case
`
`deadlines for an additional fourteen (14) days to allow for completion of the settlement agreement
`
`
`
`
`
`Case 2:21-cv-00072-JRG-RSP Document 366 Filed 02/25/22 Page 2 of 4 PageID #: 23218
`
`and to file dismissal documents with the Court. The Parties have participated in a follow-up
`
`session with Judge David Folsom, and they have scheduled an upcoming drafting session with
`
`Judge Folsom to address any outstanding issues.
`
`WHEREFORE, the Parties respectfully request that the Court enter the proposed order
`
`submitted with this Motion as set forth above
`
`
`Dated: February 25, 2022
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`/s/ Alfred R. Fabricant
`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
`
`
`
`
`2
`
`
`
`Case 2:21-cv-00072-JRG-RSP Document 366 Filed 02/25/22 Page 3 of 4 PageID #: 23219
`
` /s/ Mark N. Reiter (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
`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 366 Filed 02/25/22 Page 4 of 4 PageID #: 23220
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that on February 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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