`
`
`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 FIRST EXTENSION OF STAY
`OF ALL DEADLINES PENDING SETTLEMENT
`
`
`Plaintiff AGIS Software Development LLC (“Plaintiff” or “AGIS”) and Defendants
`
`
`
`
`
`
`
`
`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 Corporation 1 (collectively,
`
`“Panasonic” or “Defendants”) (Plaintiff and Defendants, collectively, the “Parties”) file this Joint
`
`Motion for First Extension of Stay of all Deadlines Pending Settlement.
`
`
`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 56 Filed 06/25/24 Page 2 of 4 PageID #: 991
`
`The Parties respectfully notify the Court that all matters in controversy between the Parties
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`in this case have been settled in principle. On May 21, 2024 AGIS filed a Joint Motion to Stay All
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`Deadlines and provided notice of settlement (Dkt. 54). On May 28, 2024 this Court stayed the case
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`for thirty (30) days until June 27, 2024 (Dkt. 55) while the Parties worked on a settlement
`
`agreement.
`
`The Parties are in the process of formalizing the settlement agreement, and respectfully
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`and jointly request that the Court extend the stay of all case deadlines between AGIS and Panasonic
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`for an additional thirty (30) days to allow the Parties to finalize the settlement documents. The
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`additional time is needed to have representatives of the Parties confirm/execute the settlement
`
`documents, and to file dismissal documents with the Court.
`
`WHEREFORE, the Parties respectfully request that the Court enter the proposed order
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`submitted with this motion as set forth above.
`
`
`Dated: June 25, 2024
`
`
`
`
`
`
`
`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
`
`
`
`
`
`
`
`Case 2:22-cv-00443-JRG Document 56 Filed 06/25/24 Page 3 of 4 PageID #: 992
`
`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
`
`
`
`
` /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
`
`
`
`
`
`
`Case 2:22-cv-00443-JRG Document 56 Filed 06/25/24 Page 4 of 4 PageID #: 993
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that, on June 25, 2024, all counsel of record who are
`
`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).
`
`
`
`
`
`
`
`/s/ Alfred R. Fabricant
` Alfred R. Fabricant
`
`
`
`CERTIFICATE OF CONFERENCE
`
`The undersigned hereby certifies that counsel for Plaintiff has met and conferred with
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`counsel for Defendants, and the Parties have agreed to the proposed order submitted herewith.
`
`
`
`
`/s/ Alfred R. Fabricant
` Alfred R. Fabricant
`
`
`
`
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