Data Scape Limited v. Apple, Inc.

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

Joint MOTION to Stay 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 STAY ALL PROCEEDINGS AND NOTICE OF SETTLEMENT BETWEEN PLAINTIFF DATA SCAPE LIMITED AND DEFENDANT APPLE INC. Plaintiff Data Scape Limited ("Data Scape") and Defendant Apple Inc. ("Defendant") file this Joint Motion to Stay All Deadlines and Notice of Settlement 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 thirty (30) days as between Data Scape and Apple. All matters in controversy between Data Scape and Apple have been settled, in principle, and the parties respectfully request that the Court stay all unreached deadlines in the Docket Control Order for thirty (30) days as between Data Scape and Apple so that they may finalize a long-form settlement agreement and submit appropriate dismissal papers. For the foregoing reasons, the Parties pray that the Court grant this motion. Dated: August 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 SERVICE The undersigned certifies that on August 6, 2019 all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system pursuant to Local Rule CV-5(a)(3)(A). /s/ J. Stephen Ravel J. Stephen Ravel 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