`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`Civil Action No.: 2:13-cv-1059-JRG
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`JURY TRIAL DEMANDED
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`SOLOCRON MEDIA, LLC,
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`Plaintiff,
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`v.
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`VERIZON COMMUNICATIONS INC., et al.,
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`Defendants.
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`STIPULATED MOTION FOR DISMISSAL WITH PREJUDICE
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`The plaintiff, Solocron Media LLC and defendant AT&T Mobility LLC, pursuant to Fed.
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`R. Civ. P. 41(a)(2) and (c), hereby move for an order dismissing all claims in this action WITH
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`PREJUDICE and dismissing all counterclaims as MOOT, with each party to bear its own costs,
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`expenses and attorneys fees.
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`Dated: May 15, 2015
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`Respectfully submitted,
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`/s/ William P. Nelson
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`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.)
`Paul T. Ehrlich
`CA Bar No. 228543 (Admitted E.D. Tex.)
`William P. Nelson* Lead Attorney
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`1
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`Case 2:13-cv-01059-JRG-RSP Document 192 Filed 05/15/15 Page 2 of 3 PageID #: 4568
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`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/ Scott W. Hejny
`Theodore Stevenson, III
`Lead Attorney
`Texas State Bar No. 19196650
`tstevenson@mckoolsmith.com
`Scott W. Hejny
`Texas State Bar No. 24038952
`shejny@mckoolsmith.com
`Nicholas Mathews
`Texas State Bar No. 24085457
`nmathews@mckoolsmith.com
`Warren Lipschitz
`Texas State Bar No. 24078867
`wlipschitz@mckoolsmith.com
`Charles E. Fowler, Jr.
`Texas State Bar No. 24083014
`cfowler@mckoolsmith.com
`MCKOOL SMITH, P.C.
`300 Crescent Court, Suite 1500
`Dallas, Texas 75201
`Telephone: (214) 978-4000
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`2
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`Case 2:13-cv-01059-JRG-RSP Document 192 Filed 05/15/15 Page 3 of 3 PageID #: 4569
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`Telecopier: (214) 978-4044
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`ATTORNEYS FOR AT&T MOBILITY LLC
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that the foregoing document was filed electronically in
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`compliance with Local Rule CV-5(a) on May 15, 2015. As such, this document was served on
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`all counsel who are deemed to have consented to electronic service. Local Rule CV-5(a)(3)(A).
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`/s/ Scott W. Hejny
`Scott W. Hejny
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`3
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