`
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`
`Plaintiff,
`
`
`HMD GLOBAL, ET AL.,
`
`
`v.
`
`Defendants.
`
`
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`§
`
`§
`Case No. 2:22-cv-00443-JRG
`§
`(LEAD CASE)
`§
`
`JURY TRIAL DEMANDED
`§
`§
`
`§
`§
`§
`§
`§
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`JOINT MOTION FOR STAY OF ALL DEADLINES AND NOTICE OF SETTLEMENT
`
`Plaintiff AGIS Software Development LLC (“Plaintiff” or “AGIS”) and Defendant
`
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`
`Plaintiff,
`
`
`
`v.
`
`
`PANASONIC CORPORATION, ET AL.,
`
`
`Defendants.
`
`
`Case No. 2:22-cv-00447-JRG-RSP
`(MEMBER CASE)
`
`JURY TRIAL DEMANDED
`
`
`Panasonic Corporation of North America and Panasonic Holdings Corporation1 (collectively,
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`“Panasonic”) (Plaintiff and Defendants, collectively, the “Parties”) have met and conferred and
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`jointly submit this request for a stay of all case deadlines.
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`The Parties hereby notify the Court that AGIS and Panasonic have reached an agreement
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`in principle to settle all remaining claims and counterclaims for relief in this litigation.
`
`
`1 AGIS named Panasonic Corporation as a defendant in this lawsuit. However, Panasonic
`Corporation of North America’s parent company is a different Panasonic entity, Panasonic
`Holdings Corporation.
`
`
`
`
`
`Case 2:22-cv-00443-JRG Document 54 Filed 05/21/24 Page 2 of 4 PageID #: 983
`
`Accordingly, the Parties jointly move the Court to enter a stay of all deadlines in the case,
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`including as set forth in the Court’s Docket Control Order (Dkt. 33), for thirty (30) days to allow
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`the settlement to be finalized and dismissal papers to be submitted. This stay is not sought for the
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`purpose of delay, but so that justice may be served.
`
`
`Dated: May 21, 2024
`
`
`
`
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`
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`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 Avenue,
`Suite 206 South
`Rye, New York 10580
`Telephone: (212) 257-5797
`Facsimile: (212) 257-5796
`
`Justin Kurt Truelove
`State Bar No. 24013653
`Email: kurt@truelovelawfirm.com
`TRUELOVE LAW FIRM, PLLC
`100 West Houston Street
`Marshall, Texas 75670
`Telephone: (903) 938-8321
`Facsimile: (903) 215-8510
`
`ATTORNEYS FOR PLAINTIFF AGIS
`SOFTWARE DEVELOPMENT LLC
`
`
`
`
`
`
`2
`
`
`
`Case 2:22-cv-00443-JRG Document 54 Filed 05/21/24 Page 3 of 4 PageID #: 984
`
`
`
` /s/ Trey Yarbrough (with permission)
`Trey Yarbrough
`Bar No. 22133500
`Email: trey@yw-lawfirm.com
`YARBROUGH WILCOX, PLLC
`100 E. Ferguson, Suite 1015
`Tyler, Texas 75702
`Telephone: 903-595-3111
`Facsimile: 903-595-0191
`
`Michael J. Kasdan
`Joseph M. Casino
`WIGGIN AND DANA, LLP
`437 Madison Avenue, 35th Floor
`New York, NY 10022
`Telephone: 212.551-2603
`Facsimile: 212.551.2888
`
`ATTORNEY FOR DEFENDANTS
`PANASONIC HOLDINGS CORPORATION
`AND PANASONIC CORPORATION OF
`NORTH AMERICA
`
`
`
`
`3
`
`
`
`Case 2:22-cv-00443-JRG Document 54 Filed 05/21/24 Page 4 of 4 PageID #: 985
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that, on May 21, 2024, all counsel of record who are
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`deemed to have consented to electronic service are being served with a copy of this document via
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`the Court’s CM/ECF system per Local Rule CV-5(a)(3).
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`
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`
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`
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`/s/ Alfred R. Fabricant
` Alfred R. Fabricant
`
`
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`CERTIFICATE OF CONFERENCE
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`The undersigned hereby certifies that counsel for Plaintiff has met and conferred with
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`counsel for Defendant, and the parties have agreed to the proposed order submitted herewith.
`
`
`
`/s/ Alfred R. Fabricant
` Alfred R. Fabricant
`
`
`
`
`
`
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