Uniloc USA, Inc. et al v. NATIONAL INSTRUMENTS CORP. et al

Filing 293

Agreed MOTION to Stay All Deadlines for Defendant Filemaker, Inc. by Uniloc Singapore Private Limited. (Attachments: # 1 Text of Proposed Order)(Hartsell, Steven)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TEXAS
TYLER DIVISION
UNILOC USA, INC., et al.
Civ. Action No.: 6:10-cv-00472
Plaintiffs,
v.

JURY TRIAL DEMANDED

NATIONAL INSTRUMENTS CORP., et al.
Defendants.

AGREED MOTION FOR STAY OF ALL
DEADLINES FOR DEFENDANT FILEMAKER, INC.
Plaintiffs Uniloc USA, Inc. and Uniloc Singapore Limited (“Uniloc”) file this Agreed
Motion for Stay of All Deadlines in said cause and respectfully request a stay of all deadlines
between Uniloc and Defendant Filemaker, Inc. (“Filemaker”). The parties have reached a
settlement and a motion to dismiss Filemaker with prejudice shall be filed upon completion of
certain settlement terms, which is expected to be within the next 35 days. Filemaker agrees to
the relief sought by this motion.
WHEREFORE, PREMISES CONSIDERED, Uniloc prays that the Court enter the
attached order and stay all pending deadlines between Uniloc and Defendant Filemaker through
and including December 12, 2011.

Dated: November 7, 2011.

By:
/s/ Steven W. Hartsell
Edward R. Nelson, III
Texas State Bar No. 00797142
Barry J. Bumgardner
Texas State Bar No. 24041918
Steven W. Hartsell
Texas State Bar No. 24040199
S. Brannon Latimer
Texas State Bar No. 24060137
Jaime K. Olin

Texas State Bar No. 24070363
NELSON BUMGARDNER CASTO, P.C.
3131 West 7th Street, Suite 300
Fort Worth, Texas 76107
[phone]
[phone] (fax)
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
T. John Ward, Jr.
Texas State Bar No. 00794818
J. Wesley Hill
Texas State Bar No. 24032294
WARD & SMITH LAW FIRM
111 West Tyler St.
Longview, Texas 75601
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
ATTORNEYS FOR PLAINTIFFS
UNILOC USA, INC. AND
UNILOC SINGAPORE PRIVATE LIMITED

CERTIFICATE OF SERVICE
I hereby certify that on the 7th day of November 2011, I electronically filed the foregoing
document with the clerk of the court for the U.S. District Court, Eastern District of Texas, Tyler
Division, using the electronic case filing system of the court. The electronic case filing system
sent a “Notice of Electronic Filing” to the attorneys of record who have consented in writing to
accept this Notice as service of this document by electronic means.
/s/ Steven W. Hartsell
Steven W. Hartsell

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