`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`Plaintiff,
`
`Defendant.
`
`Case No. 6:21-cv-00158-ADA
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`
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`
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`MAXELL, LTD.,
`
`v.
`
`APPLE INC.,
`
`
`
`
`JOINT MOTION TO DISMISS
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`
`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
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`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.
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`
`
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`
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`Case 6:21-cv-00158-ADA Document 14 Filed 03/24/21 Page 2 of 3
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`Dated: March 24, 2021
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`Respectfully submitted,
`
`/s/ Michael Chibib
`Michael Chibib
`Texas Bar No. 00793497
`Ryan B. McBeth
`Texas Bar No. 24078955
`BRACEWELL LLP
`111 Congress Avenue, Suite 2300
`Austin, Texas 78701
`Telephone: (512) 472-7800
`Facsimile: (800) 404-3970
`michael.chibib@bracewell.com
`ryan.mcbeth@bracewell.com
`
`Jamie B. Beaber
`Pro Hac Vice Application to be Filed
`James A. Fussell, III
`MAYER BROWN LLP
`1999 K Street, NW
`Washington, DC 20006
`Telephone: (202) 263-3000
`Facsimile: (202) 263-3300
`jbeaber@mayerbrown.com
`jfussell@mayerbrown.com
`
`Geoff Culbertson
`Kelly Tidwell
`Patton, Tidwell & Culbertson, LLP
`2800 Texas Boulevard (75503)
`Post Office Box 5398
`Texarkana, TX 75505-5398
`Telephone: (903) 792-7080
`Facsimile: (903) 792-8233
`gpc@texarkanalaw.com
`kbt@texarkanalaw.com
`
`Counsel for Plaintiff Maxell, Ltd.
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`2
`
`
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`Case 6:21-cv-00158-ADA Document 14 Filed 03/24/21 Page 3 of 3
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`Dated: March 24, 2021
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`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.
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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
`electronic mail pursuant to Local Rule CV-5(d).
`
`/s/ Michael Chibib
`Michael Chibib
`
`3
`
`
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