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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
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`CIVIL ACTION NO. 4:17-CV-141 ALM
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`JURY TRIAL DEMANDED
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`PLECTRUM LLC,
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`Plaintiff,
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`v.
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`ORACLE CORPORATION and
`ORACLE AMERICA, INC.
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`Defendants.
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`JOINT MOTION TO STAY ALL DEADLINES AND NOTICE OF SETTLEMENT AS
`TO ORACLE
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`Plaintiff Plectrum LLC (“Plectrum”) and Defendants Oracle Corporation and Oracle
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`America, Inc. (“Oracle”) hereby submit this Joint Motion To Stay All Deadlines and Notice of
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`Settlement and show:
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`(1) Plectrum and Oracle have reached a settlement in principle and expect to enter into an
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`agreement that will resolve this action.
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`(2) Accordingly, Plectrum and Oracle submit that the Court’s resources would best be
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`served by a temporary stay of all unreached deadlines for a period of thirty (30) days
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`so that the announced settlement in principle may be completed and appropriate
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`dismissal papers thereafter filed with the Court.
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`WHEREFORE, Plectrum and Oracle request the Court grant this Joint Motion To Stay
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`All Deadlines and Notice of Settlement and enter an Order granting a temporary stay of all
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`upcoming deadlines as to the Oracle litigation for a period of thirty (30) days.
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`Case 4:17-cv-00141-ALM Document 22 Filed 06/08/17 Page 2 of 3 PageID #: 262
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`Dated: June 8, 2017
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`Respectfully submitted,
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`/s/ Zachariah S. Harrington
`Zachariah S. Harrington
`Texas Bar No. 24057886
`zac@ahtlawfirm.com
` Matthew J. Antonelli
` Texas Bar No. 24068432
` matt@ahtlawfirm.com
`Larry D. Thompson, Jr.
`Texas Bar No. 24051428
`larry@ahtlawfirm.com
`Michael D. Ellis
`Texas Bar No. 24081586
`michael@ahtlawfirm.com
`ANTONELLI, HARRINGTON &
`THOMPSON LLP
`4306 Yoakum Blvd., Ste. 450
`Houston, TX 77006
`(713) 581-3000
`
`Stafford Davis
`State Bar No. 24054605
`sdavis@stafforddavisfirm.com
`THE STAFFORD DAVIS FIRM
`The People's Petroleum Building
`102 North College Avenue, 13th Floor
`Tyler, Texas 75702
`(903) 593-7000
`(903) 705-7369 fax
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`Attorneys for Plectrum LLC
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`By: /s/ James W. Morando
`James W. Morando
`Farella Braun + Martel LLP
`235 Montgomery Street, 17th Floor
`San Francisco, California 94104
`Telephone: (415) 954-4400
`Facsimile: (415) 954-4480
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`Melissa R. Smith
`Gilliam & Smith LLP
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`2
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`Case 4:17-cv-00141-ALM Document 22 Filed 06/08/17 Page 3 of 3 PageID #: 263
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`303 South Washington Avenue
`Marshall, Texas 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
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`Counsel for Oracle Corporation and Oracle
`America, Inc.
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that 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) this 8th day of June, 2017.
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`/s/ Zachariah S. Harrington
`Zachariah S. Harrington
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`CERTIFICATE OF CONFERENCE
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`The undersigned hereby certifies that counsel for Plectrum and counsel for Oracle
`conferred and all parties agree to filing this as a joint motion.
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`/s/ Zachariah S. Harrington
`Zachariah S. Harrington
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`3
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