ECeipt LLC v. Old Navy, LLC

Western District of Texas, txwd-6:2019-cv-00258

Joint MOTION to Dismiss by eCeipt LLC.

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UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION ECEIPT LLC, Plaintiff Case No. 6:19-cv-00258-ADA v. JURY TRIAL DEMANDED OLD NAVY, LLC, Defendant JOINT MOTION TO DISMISS WITH PREJUDICE Plaintiff, eCeipt LLC, and Defendant, Old Navy, LLC have resolved their disputes in this action. Pursuant to this resolution, the parties hereby move the Court to dismiss with prejudice all claims asserted by Plaintiff against Defendant in this action and all claims asserted by Defendant against Plaintiff in this action. The parties agree that all attorneys' fees, costs of court and expenses shall be borne by the incurring party. Therefore, eCeipt LLC and Old Navy, LLC respectfully request that the Court enter an order dismissing with prejudice all claims in this action, ruling that all attorneys' fees, costs of court and expenses shall be borne by the incurring party. Dated: November 19, 2019 Respectfully submitted, Raymond W. Mort, III Texas State Bar No. 00791308 raymort@austinlaw.com THE MORT LAW FIRM, PLLC 100 Congress Ave, Suite 2000 Austin, Texas 78701 Tel/Fax: (512) 865-7950 ATTORNEYS FOR PLAINTIFF John A. "Andy" Powell Texas State Bar No. 24029775 powell@namanhowell.com NAMAN HOWELL SMITH & LEE, PLLC 400 Austin Ave., Suite 800 Waco, Texas 76701 Telephone: (254) 755-4245 Fax: (254) 754-6331 Robert T. Cruzen (Pro Hac Vice) Oregon State Bar No. 080167 rob.cruzen@klarquist.com Klaus H. Hamm (Pro Hac Vice) Oregon State Bar No. 091730 klaus.hamm@klarquist.com KLARQUIST SPARKMAN, LLP 121 S.W. Salmon Street, Suite 1600 Portland, OR 97204 Telephone: (503) 595-5300 Fax: (503) 595-5301 ATTORNEYS FOR DEFENDANT JOINT MOTION TO DISMISS WITH PREJUDICE PAGE |2