`23499
`
`Exhibit 6
`
`
`
`Case 2:21-cv-00072-JRG-RSP Document 373-6 Filed 03/29/22 Page 2 of 4 PageID #:
`23500
`
`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`[EXTERNAL EMAIL]
`
`Counsel,
`
`Enrique Iturralde <eiturralde@fabricantllp.com>
`Wednesday, March 9, 2022 6:44 PM
`Salpietra, Bethany; AGIS
`DL Lyft AGIS
`Re: AGIS v Lyft (2:21-cv-00072 (Lead)) - Bill of Costs
`
`The below requests concern separate matters. We respond here to requests in AGIS v. Lyft (EDTX).
`
`AGIS objects to the proposed bill of costs. In addition to Lyft's inability to show it is a "prevailing party," none of the
`costs are associated with any trial preparation or event because this matter did not proceed as far. None of the items
`were necessary or "for use in this case."
`
`Regarding fees, we have not received your basis to request fees.
`
`We are available to confer on the above issues tomorrow at 3:30pm Eastern.
`
`Regards,
`Enrique
`
`From: Salpietra, Bethany <Bethany.Salpietra@BakerBotts.com>
`Sent: Tuesday, March 8, 2022 11:51 PM
`To: Enrique Iturralde <eiturralde@fabricantllp.com>; AGIS <AGIS@fabricantllp.com>
`Cc: DL Lyft AGIS <DLLyftAGIS@BakerBotts.com>
`Subject: RE: AGIS v Lyft (2:21-cv-00072 (Lead)) - Bill of Costs
`
`Counsel,
`
`I’m following up on your email below regarding scheduling a meet and confer to discuss AGIS’s objections to
`Lyft’s proposed Bill of Costs. In addition to this particular issue, Lyft would also like to discuss the following
`topics for discussion at the upcoming meet and confer:
`
` AGIS’s position regarding Lyft’s motion for fees under 35 U.S.C. 285 in the EDTX case;
` AGIS’s deficient interrogatory responses in the NDCA case which could impact the case schedule and
`the proposed March 22 deposition date;
` AGIS’s refusal to produce EDTX materials in the NDCA case;
`adding AGIS, Inc., AGIS Holdings, and Malcom K. Beyer, Jr. as parties to the amended complaint; and
`
` AGIS’s position regarding a stay in NDCA case in light of pending EPR and IPR proceedings.
`
`Thanks,
`
`Bethany
`
`Bethany R. Salpietra (Ford)
`Senior Associate
`
`1
`
`
`
`Case 2:21-cv-00072-JRG-RSP Document 373-6 Filed 03/29/22 Page 3 of 4 PageID #:
`23501
`Baker Botts L.L.P.
`bethany.salpietra@bakerbotts.com
`T +1.214.953.6765
`F +1.214.661.4765
`M +1.214.435.9019
`2001 Ross Ave., Ste. 900
`Dallas, TX 75201
`USA
`
`From: Enrique Iturralde <eiturralde@fabricantllp.com>
`Sent: Sunday, March 6, 2022 10:35 PM
`To: Salpietra, Bethany <Bethany.Salpietra@BakerBotts.com>; AGIS <AGIS@fabricantllp.com>
`Cc: DL Lyft AGIS <DLLyftAGIS@BakerBotts.com>
`Subject: Re: AGIS v Lyft (2:21-cv-00072 (Lead)) - Bill of Costs
`
`[EXTERNAL EMAIL]
`
`Counsel,
`
`We do object. We will provide our availability to confer this week.
`
`Regards,
`Enrique
`
`From: Salpietra, Bethany <Bethany.Salpietra@BakerBotts.com>
`Sent: Monday, February 28, 2022 6:32 PM
`To: AGIS <AGIS@fabricantllp.com>
`Cc: DL Lyft AGIS <DLLyftAGIS@BakerBotts.com>
`Subject: AGIS v Lyft (2:21-cv-00072 (Lead)) - Bill of Costs
`
`Counsel,
`
`As you are likely aware, the Court issued an Order (Dkt. 367) last week regarding the parties’ joint motion for
`extension, which requires Lyft to file its motion for costs and fees on or before March 25, 2022. In preparation
`of filing its motion, Lyft would like to understand whether AGIS has any objections to any costs identified in
`Lyft’s proposed Bill of Costs that was previously sent on January 31, 2022 (reattached here). If there are
`objections, we’d like to set a time to meet and confer to discuss such objections. We can be available to meet
`and confer this week.
`
`Thanks in advance,
`
`Bethany
`Bethany R. Salpietra (Ford)
`Senior Associate
`Baker Botts L.L.P.
`
`2
`
`
`
`Case 2:21-cv-00072-JRG-RSP Document 373-6 Filed 03/29/22 Page 4 of 4 PageID #:
`23502
`bethany.salpietra@bakerbotts.com
`T +1.214.953.6765
`F +1.214.661.4765
`M +1.214.435.9019
`2001 Ross Ave., Ste. 900
`Dallas, TX 75201
`USA
`
`Confidentiality Notice:
`The information contained in this email and any attachments is intended only for the recipient[s] listed above and may be privileged
`and confidential. Any dissemination, copying, or use of or reliance upon such information by or to anyone other than the recipient[s]
`listed above is prohibited. If you have received this message in error, please notify the sender immediately at the email address
`above and destroy any and all copies of this message.
`Couns
`
`3
`
`
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