Parallel Networks, LLC v. Adidas America, Inc. et al

Filing 318

NOTICE of Voluntary Dismissal by Parallel Networks, LLC (Attachments: #1 Text of Proposed Order)(Tadlock, Charles)

Parallel Networks, LLC v. Adidas America, Inc. et al

Doc. 318

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION Parallel Networks, LLC, Plaintiff, v. Adidas America, Inc., et al., Defendants. NOTICE OF DISMISSAL OF COMPLAINT AGAINST DEFENDANT JONES INVESTMENT CO., INC. WITHOUT PREJUDICE Pursuant to Rule 41(a)(1), Fed.R.Civ.P., Plaintiff Parallel Networks, LLC ("Parallel Networks") hereby serves notice upon the Court of a dismissal without prejudice of the complaint against Jones Investment Company, Inc.1 Jones Investment Company, Inc. has not answered, and has not filed a motion for summary judgment. Upon representation of counsel for Jones Investment Company, Inc., and Jones Retail Corporation (now known as JAG Footwear Apparel Retail, who has already answered), Jones Investment Company, Inc. does no business in Texas and is not a proper entity to be sued, and, without admitting any allegations or liability, that Jones Retail Corporation (now known as JAG Footwear Apparel Retail) is the proper corporate entity to be sued for purposes of the allegations asserted in the complaint. Only
Defendant Jones Investment Company, Inc. is dismissed from this case by way of this Notice.

No. 6:10-cv-491-LED Jury Trial Demanded

1

The correct name of the Defendant named in the complaint is Jones Investment Co. Inc.

Dockets.Justia.com

Dated: November 24, 2010

Respectfully submitted, By: /s/ Charles Craig Tadlock Charles Craig Tadlock Texas State Bar No. 00791766 TADLOCK LAW FIRM 400 E. Royal Lane, Suite 290 Irving, Texas 75039 214-785-6014 (phone) [e-mail] and 315 N. Broadway, Suite 307 Tyler, Texas 75702 903-283-2758 (phone) George S. Bosy (pro hac vice) David R. Bennett (pro hac vice) Bosy & Bennett 300 N. La Salle St. 49th Floor Chicago, IL 60654 Telephone: [phone] Email: [e-mail] [e-mail] ATTORNEYS FOR PLAINTIFF PARALLEL NETWORKS, LLC

CERTIFICATE OF SERVICE I hereby certify that counsel of record who are deemed to have consented to electronic service are being served this 24nd day of November, 2010, with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3). Any other counsel of record will be served by electronic mail, facsimile transmission and/or first class mail on this same date. /s/ Charles Craig Tadlock Charles Craig Tadlock