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`R2 Solutions LLC,
`
`
`
`v.
`
`7-Eleven, Inc.,
`
`
`
`
`
`
`
`
`Plaintiff,
`
`Defendant.
`
`
`
`
`
`
`
`
`
`Civil Action No. 3:22-cv-02868-S
`
`JURY TRIAL DEMANDED
`
`Case 3:22-cv-02868-S Document 39 Filed 07/31/23 Page 1 of 2 PageID 677
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF TEXAS
`DALLAS DIVISION
`
`
`
`
`JOINT NOTICE OF RESOLUTION AND MOTION TO STAY
`
`Plaintiff R2 Solutions LLC, on the one hand, and Defendant 7-Eleven, Inc., on the other
`
`hand, notify the Court that they have reached an agreement in principle that resolves the claims
`
`in this case. In furtherance of their agreement, the parties expect to move to dismiss this case in
`
`the next thirty (30) days. Thus, the parties respectfully move the Court to enter an order staying
`
`all deadlines herein for thirty (30) days while they memorialize their resolution and file a motion
`
`to dismiss.
`
`DATED: July 31, 2023
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`/s/ Edward R. Nelson III
`EDWARD R. NELSON III
`State Bar No. 00797142
`ed@nelbum.com
`BRENT N. BUMGARDNER
`State Bar No. 00795272
`brent@nelbum.com
`CHRISTOPHER G. GRANAGHAN
`State Bar No. 24078585
`chris@nelbum.com
`JOHN P. MURPHY
`State Bar No. 24056024
`murphy@nelbum.com
`CARDER W. BROOKS
`
`/s/ David B. Conrad
`Neil J. McNabnay
`njm@fr.com
`Texas Bar No. 24002583
`David B. Conrad
`conrad@fr.com
`Texas Bar No. 24049042
`Ricardo J. Bonilla
`rbonilla@fr.com
`Texas Bar No. 24082704
`Michael R. Ellis
`ellis@fr.com
`Texas Bar No. 24102726
`Nan Lan
`
`

`

`Case 3:22-cv-02868-S Document 39 Filed 07/31/23 Page 2 of 2 PageID 678
`
`State Bar No. 24105536
`carder@nelbum.com
`
`NELSON BUMGARDNER CONROY PC
`3131 West 7th Street, Suite 300
`Fort Worth, Texas 76107
`817.377.9111
`
`COUNSEL FOR PLAINTIFF
`R2 SOLUTIONS LLC
`
`
`
`
`
`
`
`
`
`
`
`lan@fr.com
`Texas Bar No. 24121711
`FISH & RICHARDSON P.C.
`1717 Main Street, Suite 5000
`
`Dallas, TX 75201
`(214) 747-5070 (Telephone)
`(214) 747-2091 (Facsimile)
`
`COUNSEL FOR DEFENDANT
`7-ELEVEN, INC.
`
`
`
`CERTIFICATE OF CONFERENCE
`
`In accordance with Civil LR 7.1(b), the undersigned certifies that counsel for Plaintiff
`
`conferred with counsel for Defendant and the parties are in agreement as to the relief sought by
`
`this joint motion.
`
`/s/ Edward R. Nelson III
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that a copy of the foregoing was served on all parties of record
`
`on July 31, 2023 via the Court’s CM/ECF system.
`
`
`
`/s/ Edward R. Nelson III
`
`
`
`2
`
`
`
`

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