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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF TEXAS
`DALLAS DIVISION
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`R2 SOLUTIONS LLC,
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` Plaintiff,
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` v.
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`7-ELEVEN, INC.,
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` Defendant.
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`CASE NO. 3:22-CV-02868
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`JOINT MOTION TO EXTEND STAY
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`Plaintiff R2 Solutions LLC and Defendant 7-Eleven, Inc. (the “Parties”) notify
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`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
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`Court’s August 31, 2023 Order (ECF 42), the Parties are presently required to file
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`dismissal documents no later than today, September 6, 2022. The Parties completed
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`the signature process but need more time to finalize the dismissal documents. They
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`respectfully move the Court to enter an order extending the current stay one week to
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`September 13, 2023 and adjusting the deadline to file dismissal documents
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`accordingly.
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`1
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`Case 3:22-cv-02868-S Document 43 Filed 09/06/23 Page 2 of 2 PageID 685
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`Dated: September 6, 2023
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` Respectfully submitted,
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`/s/ Edward R. Nelson III
`Edward R. Nelson III
`Texas Bar No. 00797142
`ed@nelbum.com
`Brent N. Bumgardner
`Texas Bar No. 00795272
`brent@nelbum.com
`Christopher G. Granaghan
`Texas Bar No. 24078585
`chris@nelbum.com
`John P. Murphy
`Texas Bar No. 24056024
`murphy@nelbum.com
`Carder W. Brooks
`Texas Bar No. 24105536
`carder@nelbum.com
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`NELSON BUMGARDNER CONROY PC
`3131 West 7th Street, Suite 300
`Fort Worth, TX 76107
`817-377-9111
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`COUNSEL FOR PLAINTIFF
`R2 SOLUTIONS LLC
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`/s/ David B. Conrad
`Neil J. McNabnay
`mcnabnay@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
`lan@fr.com
`Texas Bar No. 24121711
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`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 Defendant
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`conferred with counsel for Plaintiff and that the parties are in agreement as to the relief sought by
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`this joint motion.
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`/s/ David B. Conrad
`David B. Conrad
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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 September 6, 2023 via the Court’s CM/ECF system.
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`/s/ David B. Conrad
`David B. Conrad
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