American Airlines Inc v. Travelport Limited et al

Filing 3

NOTICE OF OTHER LITIGATION filed by American Airlines Inc (Yetter, R)

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION ) American Airlines, Inc., a Delaware Corporation, ) ) Plaintiff, ) ) vs. ) ) Travelport Limited, a foreign corporation and ) Travelport, LP, a Delaware limited partnership, ) d/b/a Travelport; ) ) and ) ) Orbitz Worldwide, LLC, a Delaware limited ) liability company, d/b/a Orbitz, ) ) ) Defendants. ) ) ) ) Civil Action No.: ______________ NOTICE OF OTHER LITIGATION Plaintiff American Airlines, Inc. (“American”) respectfully submits this Notice of Other Litigation. In its Complaint, filed contemporaneously with this Notice, American refers to a several lawsuits that it is currently involved in. While these lawsuits are not “related cases” as defined in Local Civil Rule 3.3(b), American files this Notice of Other Litigation to provide additional details on them. 1. On November 5, 2010, Travelport, LP sued American in the Circuit Court of Cook County, Illinois, County Department, Chancery Division, Case No. 10-CH-48028, currently before the Honorable Lee Preston, with respect to contract compliance. On November 19, 2010, the Court issued a Temporary Restraining Order. On December 21, 2010, the Court dissolved the Temporary Restraining Order and denied preliminary injunctive relief. Travelport, LP’s claims are pending. 2. On November 5, 2010, American sued Travelport, Inc. in the 67th Judicial District Court of Tarrant County, Texas, Cause No. 067-249214-10, before the Honorable Don Cosby, Jr., with respect to contract compliance. On January 13, 2010, American nonsuited Travelport, Inc. without prejudice. 3. On December 30, 2010, American brought counterclaims in the Circuit Court of Cook County, Illinois, County Department, Chancery Division, against Travelport, LP in Case No. 10-CH-48028, with respect to contract compliance and violations of the Illinois Deceptive Trade Practices Act. American’s claims are pending. 4. On January 10, 2011, American filed an Amended Original Petition and Application for TRO and Temporary Injunction in Cause No. 067-249214-10 in the 67th Judicial District Court of Tarrant County, Texas, in which it sued Sabre Inc., Sabre Holdings, Inc., and Sabre Travel International Limited with respect to contract compliance and tortious conduct. That day, the Court issued a Temporary Restraining Order. On January 26, 2011, by Agreed Order, this case was abated until June 1, 2011. 2 DATED: April 12, 2011 Respectfully submitted, /s/ R. Paul Yetter_______________ R. Paul Yetter State Bar No. 22154200 pyetter@yettercoleman.com Anna Rotman State Bar No. 24046761 arotman@yettercoleman.com YETTER COLEMAN LLP 909 Fannin, Suite 3600 Houston, Texas 77010 713.632.8000 713.632.8002 (Fax) Of Counsel: DEWEY & LEBOEUF LLP M.J. Moltenbrey mmoltenbrey@dl.com 1101 New York Ave. NW Washington, D.C. 20005 202.346.8738 202.346.8102 (Fax) WEIL, GOTSHAL & MANGES Richard A. Rothman richard.rothman@weil.com James W. Quinn james.quinn@weil.com 767 Fifth Avenue New York, New York 10153 212.310.8426 212.310.8285 (Fax) Bill Bogle State Bar No. 02561000 bbogle@hfblaw.com Roland K. Johnson State Bar No. 00000084 rolandjohnson@hfblaw.com HARRIS, FINLEY & BOGLE, P.C. 777 Main Street, Suite 3600 Fort Worth, Texas 76102 817.870.8700 817.332.6121 (Fax) Michelle Hartmann State Bar No. 24032402 michelle.hartmann@weil.com WEIL, GOTSHAL & MANGES 200 Crescent Court, Suite 300 Dallas, Texas 75201-6950 214.746.7700 214.746.7777 (Fax) ATTORNEYS FOR PLAINTIFF AMERICAN AIRLINES, INC. CERTIFICATE OF SERVICE No appearance has been made by a lawyer representing Defendants; therefore, this Notice of Other Litigation is being served with the Summons. /s/ R. Paul Yetter_______________ 3

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