Data Scape Limited v. Apple, Inc.

Western District of Texas, txwd-6:2019-cv-00310

Joint MOTION to Stay Case Extension of Stay Pending Dismissal by Apple, Inc.

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UNITED STATES DISTRICT COURT IN THE WESTERN DISTRICT OF TEXAS WACO DIVISION § DATA SCAPE LIMITED, § § PLAINTIFF, § § v. § CASE NO. 6:19-CV-00310-ADA § APPLE INC., § § DEFENDANT. § § JOINT MOTION TO EXTEND STAY PENDING DISMISSAL Plaintiff Data Scape Limited ("Data Scape") and Defendant Apple Inc. ("Defendant") file this Joint Motion to Extend Stay Pending Dismissal as between Data Scape and Apple and respectfully move this Court to stay all unreached deadlines in the case, including the deadline for Apple to respond to the complaint, for an additional thirty (30) days as between Data Scape and Apple. All matters in controversy between Data Scape and Apple have been settled. The documentation allowing the dismissal of this cause is substantially but not completely finalized. Accordingly, the parties respectfully request that the Court stay all unreached deadlines in the Docket Control Order for an additional thirty (30) days as between Data Scape and Apple so that they may submit appropriate dismissal papers. For the foregoing reasons, the Parties pray that the Court grant this motion. Dated: September 6, 2019 Respectfully submitted, By: /s/ J. Stephen Ravel J. Stephen Ravel Texas State Bar No. 16584975 J.R. Johnson Texas State Bar No. 24070000 KELLY HART & HALLMAN LLP 303 Colorado, Suite 2000 Austin, Texas 78701 Tel: (512) 495-6400 Fax: (512) 495-6401 Email: steve.ravel@kellyhart.com Email: jr.johnson@kellyhart.com ATTORNEYS FOR DEFENDANT APPLE INC. CERTIFICATE OF CONFERENCE The undersigned certifies counsel conferred and Plaintiff's counsel agreed to the relief sought. Accordingly, this motion and the relief requested herein is joint. /s/ J Stephen Ravel J. Stephen Ravel