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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
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`MAXELL LTD.,
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`ZTE (USA) INC.,
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`Plaintiff,
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`v.
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`Defendant.
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`Case No. 5:16-cv-00179-RWS
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`JURY TRIAL DEMANDED
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`JOINT MOTION TO STAY ALL DEADLINES AND NOTICE OF SETTLEMENT
`For their Joint Motion to Stay all Deadlines and Notice of Settlement, Maxell Ltd.
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`(“Maxell”) and ZTE (USA) Inc. (“ZTE”) respectfully state as follows:
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`All matters in controversy between the parties have been settled in principle.
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`Accordingly, the parties request that the Court stay all pending deadlines for thirty days so that
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`the appropriate dismissal papers may be submitted. The parties stipulate that if any issues arise
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`prior to dismissal, the parties will submit those to the Court for final resolution. The parties make
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`this request to allow for the orderly completion of their agreement and not for purposes of delay.
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`Because confidentiality is a material term of the parties’ agreement, the parties’
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`memorandum of understanding is filed under seal as Exhibit A pursuant to the Standing Order
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`Regarding Proper Notification of Settlement to Court in Cases Pending Before Judge Robert
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`Schroeder.
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`Respectfully submitted,
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`1
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`Case 5:16-cv-00179-RWS Document 303 Filed 02/04/19 Page 2 of 5 PageID #: 19895
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`Dated: February 4, 2019
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`2
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`By:
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`/s/ Geoff Culbertson
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`Geoffrey P. Culbertson
`Kelly Tidwell
`Patton, Tidwell & Culbertson, LLP
`2800 Texas Boulevard (75503)
`Post Office Box 5398
`Texarkana, TX 75505-5398
`Telephone: (903) 792-7080
`Facsimile: (903) 792-8233
`gpc@texarkanalaw.com
`kbt@texarkanalaw.com
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`Jamie B. Beaber
`Alan M. Grimaldi
`Kfir B. Levy
`James A. Fussell, III
`Baldine B. Paul
`Tiffany A. Miller
`William J. Barrow
`Saqib Siddiqui
`Brian C. Nese
`MAYER BROWN LLP
`1999 K Street, NW
`Washington, DC 20006
`Telephone: (202) 263-3000
`Facsimile: (202) 263-3300
`jbeaber@mayerbrown.com
`agrimaldi@mayerbrown.com
`klevy@mayerbrown.com
`jfussell@mayerbrown.com
`bpaul@mayerbrown.com
`tmiller@mayerbrown.com
`wbarrow@mayerbrown.com
`ssiddiqui@mayerbrown.com
`bnese@mayerbrown.com
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`Robert G. Pluta
`Amanda S. Bonner
`MAYER BROWN LLP
`71 S. Wacker Drive
`Chicago, IL 60606
`(312) 782-0600
`rpluta@mayerbrown.com
`asbonner@mayerbrown.com
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`Counsel for Plaintiff Maxell, Ltd.
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`Case 5:16-cv-00179-RWS Document 303 Filed 02/04/19 Page 3 of 5 PageID #: 19896
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`/s/ Lionel M. Lavenue
`Lionel M. Lavenue
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`Lionel M. Lavenue
`VA State Bar No. 49,005
`FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, LLP
`Two Freedom Square
`11955 Freedom Drive
`Reston, VA 20190
`Phone: (571) 203-2700
`Fax: (202) 408-4400
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`ATTORNEY FOR DEFENDANT
`ZTE (USA) INC.
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`3
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`Case 5:16-cv-00179-RWS Document 303 Filed 02/04/19 Page 4 of 5 PageID #: 19897
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that all counsel of record who are deemed to have consented to
`electronic service are being served this 4th day of February, 2019, with a copy of this document
`via the Court’s CM/ECF system.
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`/s/ Geoff Culbertson
`Geoffrey P. Culbertson
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`4
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`Case 5:16-cv-00179-RWS Document 303 Filed 02/04/19 Page 5 of 5 PageID #: 19898
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`CERTIFICATE OF AUTHORIZATION TO FILE UNDER SEAL
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`Pursuant to Local Rule CV-5 (a(7)(A) and Judge Robert Schroeder’s Standing Order Regarding
`Proper Notification of Settlement, the undersigned counsel hereby certifies that authorization for filing
`under seal has been previously granted by the Court in this case.
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`/s/ Geoff Culbertson
`Geoffrey P. Culbertson
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`5
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