`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`Plaintiff,
`
`Defendant.
`
`Case No. 6:20-cv-00646-ADA
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`
`
`
`
`
`
`MAXELL, LTD.,
`
`v.
`
`APPLE INC.,
`
`
`
`
`JOINT MOTION TO DISMISS
`
`
`Pursuant to Rule 41(a) of the Federal Rules of Civil Procedure, Plaintiff Maxell, Ltd.
`
`(“Maxell”) and Defendant Apple Inc. (Maxell and Apple are collectively, “the Parties”), hereby
`
`jointly move for dismissal with prejudice of all claims by Maxell against Apple. The Parties further
`
`move for an order that all costs and expenses relating to this litigation up to the time of dismissal
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`shall be borne by the party incurring same. A proposed order accompanies this motion.
`
`Respectfully submitted,
`
`Dated: March 24, 2021
`
`
`
`
`
`
`
`/s/ Robert S. Harrell
`Robert S. Harrell
`MAYER BROWN LLP
`700 Louisiana Street
`Suite 3400
`Houston, TX 77002
`Telephone: (713) 238-270000
`Facsimile: (713) 238-4636
`rharrell@mayerbrown.com
`
`Jamie B. Beaber
`Pro Hac Vice Application to be Filed
`MAYER BROWN LLP
`1999 K Street, NW
`Washington, DC 20006
`
`
`
`Case 6:20-cv-00646-ADA Document 17 Filed 03/24/21 Page 2 of 3
`
`
`
`
`
`Dated: March 24, 2021
`
`
`
`Telephone: (202) 263-3000
`Facsimile: (202) 263-3300
`jbeaber@mayerbrown.com
`
`Robert G. Pluta
`Pro Hac Vice Application to be Filed
`MAYER BROWN LLP
`71 S. Wacker Drive
`Chicago, IL 60606
`(312) 782-0600
`rpluta@mayerbrown.com
`
`Counsel for Plaintiff Maxell, Ltd.
`
`
`
`Respectfully Submitted
`
`By: /s/ John M. Guaragna
`John M. Guaragna
`Texas Bar No. 24043308
`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
`
`
`
`
`
`Counsel for Defendant Apple Inc.
`
`2
`
`
`
`Case 6:20-cv-00646-ADA Document 17 Filed 03/24/21 Page 3 of 3
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`CERTIFICATE OF SERVICE
`
`The undersigned certifies that all counsel of record who are deemed to have consented to
`electronic service are being served this 24th day of March, 2021, with a copy of this document via
`the Court’s CM/ECF system per Local Rule CV-5(a)(3).
`
`
`
`
`/s/ Robert S. Harrell
`Robert S. Harrell
`
`
`
`
`
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`
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`
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