`
`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`Civil Action No. 2:13-cv-1059-JRG-RSP
`
`JURY TRIAL DEMANDED
`
`
`SOLOCRON MEDIA, LLC,
`
`
`
`
`
`VERIZON COMMUNICATIONS INC., et al.
`
`
`
`
`
`
`v.
`
`
`
`
`
`
`
`Plaintiff,
`
`Defendants.
`
`JOINT STIPULATED MOTION FOR DISMISSAL WITH PREJUDICE
`
`The Plaintiff, Solocron Media, LLC and Defendant, Verizon Communications Inc.,
`
`Cellco Partnership d.b.a. Verizon Wireless pursuant to Fed. R. Civ. P. 41(a)(2) and (c), hereby
`
`move for an order dismissing all claims in this action WITH PREJUDICE and dismissing all
`
`counterclaims as MOOT, with each party to bear its own costs, expenses and attorneys fees.
`
`
`Dated: May 6, 2015
`
`
`
`
`Respectfully submitted,
`
`
`
`/s/
`
`William P. Nelson
`
`
`
`Eric H. Findlay
`State Bar No. 00789886
`Findlay Craft, P.C.
`102 North College Avenue
`Suite 900
`Tyler, TX 75702
`Telephone: (903) 534-1100
`Facsimile: (903) 534-1137
`efindlay@findlaycraft.com
`
`Matthew D. Powers
`CA Bar No. 104795 (Admitted E.D. Tex.)
`Steven S. Cherensky
`CA Bar No. 168275 (Admitted E.D. Tex.)
`
`
`
`Case 2:13-cv-01059-JRG-RSP Document 189 Filed 05/06/15 Page 2 of 4 PageID #: 4561
`
`Paul T. Ehrlich
`CA Bar No. 228543 (Admitted E.D. Tex.)
`William P. Nelson* Lead Attorney
`CA Bar No. 196091(Admitted E.D. Tex.)
`Robert L. Gerrity
`CA Bar No. 268084 (Admitted E.D. Tex.)
`Annaka Nava
`CA Bar No. 298131 (Admitted E.D. Tex.)
`Sam Y. Kim
`CA Bar No. 282582 (Admitted E.D. Tex.)
`Natasha M. Saputo
`CA Bar No. 291151 (Admitted E.D. Tex.)
`TENSEGRITY LAW GROUP, LLP
`555 Twin Dolphin Drive, Suite 650
`Redwood Shores, CA 94065
`Telephone: (650) 802-6000
`Facsimile: (650) 802-6001
`Email:
`matthew.powers@tensegritylawgroup.com
`steven.cherensky@tensegritylawgroup.com
`paul.ehrlich@tensegritylawgroup.com
`william.nelson@tensegritylawgroup.com
`robert.gerrity@tensegritylawgroup.com
`annaka.nava@tensegritylawgroup.com
`sam.kim@tensegritylawgroup.com
`natasha.saputo@tensegritylawgroup.com
`
`
`
`
`
`/s/ Kevin P. Anderson____
`
`Michael E. Jones
`State Bar No. 10929400
`mikejones@potterminton.com
`POTTER MINTON
`A Professional Corporation
`110 N. College, Suite 500 (75702)
`P.O. Box 359
`Tyler, TX 75710
`Tel: (903) 597-8311
`Fax: (903) 593-0846
`
`Kevin P. Anderson
`kanderson@wileyrein.com
`WILEY REIN LLP
`1776 K Street, NW
`
`2
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`
`
`
`
`
`
`
`
`Case 2:13-cv-01059-JRG-RSP Document 189 Filed 05/06/15 Page 3 of 4 PageID #: 4562
`
`Washington, D.C. 20006
`Tel: (202) 719-7000
`Fax: (202) 719-7049
`
`Attorneys for Defendants Verizon Communications
`Inc. and Cellco Partnership d.b.a. Verizon
`
`
`
`3
`
`
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`
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`
`
`
`Case 2:13-cv-01059-JRG-RSP Document 189 Filed 05/06/15 Page 4 of 4 PageID #: 4563
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on May 6, 2015 I electronically filed the foregoing document with
`
`the Clerk of the Court using the CM/ECF system in compliance with Local Rule CV-5(a). As
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`such, a copy of this document was served on all counsel who are deemed to have consented to
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`electronic service. See Local Rule CV-5(a)(3)(A).
`
`
`
`
`
`
`
`
`
`By:
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`/s/ William P. Nelson_____
`William P. Nelson
`
`4
`
`
`
`Case 2:13-cv-01059-JRG-RSP Document 191 Filed 05/11/15 Page 1 of 1 PageID #: 4566
`
`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`SOLOCRON MEDIA, LLC,
`
`
`
`
`
`VERIZON COMMUNICATIONS INC., et al.
`
`
`
`
`
`
`v.
`
`
`
`
`
`
`
`Plaintiff,
`
`Defendants.
`
`Civil Action No. 2:13-cv-1059-JRG-RSP
`
`
`
`
`ORDER OF DISMISSAL WITH PREJUDICE
`
`In consideration of the parties’ Joint Stipulated Motion for Dismissal of all claims with
`
`prejudice and all counterclaims as moot asserted between Plaintiff, Solocron Media, LLC, and
`
`Defendant, Verizon Communications Inc., Cellco Partnership d.b.a. Verizon Wireless, the Joint
`
`Stipulated Motion for Dismissal is GRANTED, and it is ORDERED, ADJUDGED AND
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`DECREED that all claims asserted in this suit between Solocron Media, LLC and Defendant are
`
`hereby dismissed with prejudice and all counterclaims are dismissed as moot.
`
` It is further ORDERED that all attorneys’ fees and costs are to be borne by the
`
`party that incurred them.
`
` The Clerk is ORDERED to terminate Verizon Communications Inc., Cellco Partnership
`
`d.b.a. Verizon Wireless from the instant case.
`
`
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