`R2 Solutions LLC,
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`v.
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`7-Eleven, Inc.,
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`Plaintiff,
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`Defendant.
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`Civil Action No. 3:22-cv-02868-S
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`JURY TRIAL DEMANDED
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`Case 3:22-cv-02868-S Document 41 Filed 08/30/23 Page 1 of 2 PageID 681
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF TEXAS
`DALLAS DIVISION
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`
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`JOINT MOTION TO EXTEND STAY
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`Plaintiff R2 Solutions LLC, on the one hand, and Defendant 7-Eleven, Inc., on the other
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`hand, notify the Court that they have finalized their formal agreement that resolves the claims in
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`this case and that the agreement is in the process of being signed. Per the Court’s July 31, 2023
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`Order (ECF 40), the parties are presently required to file dismissal documents no later than
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`today, August 30, 2023. In order that the parties may complete the signature process before filing
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`dismissal documents, they respectfully move the Court to enter an order extending the current
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`stay by one week to September 6, 2023 and adjusting the deadline to file to dismissal documents
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`accordingly.
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`DATED: August 30, 2023
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`Respectfully submitted,
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`/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
`
`/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
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`
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`Case 3:22-cv-02868-S Document 41 Filed 08/30/23 Page 2 of 2 PageID 682
`
`JOHN P. MURPHY
`State Bar No. 24056024
`murphy@nelbum.com
`CARDER W. BROOKS
`State Bar No. 24105536
`carder@nelbum.com
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`NELSON BUMGARDNER CONROY PC
`3131 West 7th Street, Suite 300
`Fort Worth, Texas 76107
`817.377.9111
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`COUNSEL FOR PLAINTIFF
`R2 SOLUTIONS LLC
`
`
`Michael R. Ellis
`ellis@fr.com
`Texas Bar No. 24102726
`Nan Lan
`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)
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`COUNSEL FOR DEFENDANT
`7-ELEVEN, INC.
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`CERTIFICATE OF CONFERENCE
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`In accordance with Civil LR 7.1(b), the undersigned certifies that counsel for Plaintiff
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`conferred with counsel for Defendant and the parties are in agreement as to the relief sought by
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`this joint motion.
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`/s/ Edward R. Nelson III
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that a copy of the foregoing was served on all parties of record
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`on August 30, 2023 via the Court’s CM/ECF system.
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`/s/ Edward R. Nelson III
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`2
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