`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`NEODRON, LTD.,
`
`Case No. 6:20-cv-00212-ADA
`
`Plaintiff,
`
`PATENT CASE
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`JURY TRIAL DEMANDED
`
`UNOPPOSED MOTION TO STAY ALL DEADLINES AND NOTICE OF
`SETTLEMENT
`
`Apple Inc., files this Unopposed Motion to Stay All Deadlines and Notice of Settlement
`
`and respectfully moves this Court to stay all unreached deadlines for thirty (30) days.
`
`All matters in controversy between Apple Inc. and Neodron, Ltd. have been settled, in
`
`principle, and the parties respectfully request that the Court stay all unreached deadlines for
`
`thirty (30) days so that appropriate dismissal papers may be submitted. Plaintiff Neodron
`
`consents to the relief requested herein.
`
`Dated: December 2, 2020
`
`Respectfully submitted,
`
`/s/ John M. Guaragna
`John M. Guaragna
`Texas Bar No 24043308
`Brian K. Erickson
`Texas Bar No. 24012594
`Jeffrey Cole
`Texas Bar No. 24045679
`DLA PIPER LLP (US)
`401 Congress Avenue, Suite 2500
`Austin, TX 78701-3799
`Tel: 512.457.7125
`Fax: 512.457.7001
`john.guaragna@dlapiper.com
`brian.erickson@dlapiper.com
`
`1
`
`
`
`Case 6:20-cv-00212-ADA Document 45 Filed 12/02/20 Page 2 of 3
`
`Mark Fowler (pro hac vice)
`Robert Buergi (pro hac vice)
`DLA Piper LLP (US)
`2000 University Avenue
`East Palo Alto, CA 94303
`Tel: 650-833-2000
`Fax: 650-833-2100
`
`Erin Gibson (pro hac vice)
`DLA Piper LLP (US)
`401 B Street, Suite 1700
`San Diego, CA 92101
`Tel: 619-699-2700
`Fax: 619-699-2701
`
`James M. Heintz (pro hac vice)
`DLA Piper LLP (US)
`One Fountain Square
`11911 Freedom Drive, Suite 300
`Reston, VA 20190
`Tel: 703-773-4000
`Fax: 703-773-5000
`
`Nandan Padmanabhan (pro hac vice)
`DLA Piper LLP (US)
`2000 Avenue of the Stars, Suite 400
`North Tower
`Los Angeles, CA 90067
`Tel: 310-595-3000
`Fax: 310-595-3300
`
`Erin McLaughlin (pro hac vice)
`DLA Piper LLP (US)
`1251 Avenue of the Americas, 27th Floor
`New York, NY 10020
`Tel: 212-335-4500
`Fax: 212-335-4501
`
`ATTORNEYS FOR DEFENDANT APPLE INC.
`
`2
`
`
`
`Case 6:20-cv-00212-ADA Document 45 Filed 12/02/20 Page 3 of 3
`
`CERTIFICATE OF CONFERENCE
`
`Pursuant to Local Rule CV-7(i), counsel for Apple has conferred with counsel for
`
`Neodron, and Neodron agrees to the relief requested in the instant Motion.
`
`
`
`/s/ John M. Guaragna
`John M. Guaragna
`
`CERTIFICATE OF SERVICE
`
`I certify that the foregoing document was filed electronically on December 2, 2020,
`
`pursuant to Local Rule CV-5(a) and has been served on all counsel whom have consented to
`
`electronic service. Any other counsel of record will be served by first class U.S. mail on this same
`
`date.
`
`/s/ John M. Guaragna
`John M. Guaragna
`
`3
`
`
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