American Airlines Inc v. Travelport Limited et al

Filing 475

Joint MOTION to Stay Pending Conditions of Settlement filed by American Airlines Inc, Orbitz Worldwide, LLC (Rotman, Anna)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION
AMERICAN AIRLINES, INC.
Plaintiff,
vs.
TRAVELPORT LIMITED, et al.
Defendants.

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CIVIL ACTION NO. 4:11-CV-244-Y

AMERICAN AIRLINE INC.’S AND ORBITZ WORLDWIDE, LLC’S
JOINT MOTION FOR LIMITED STAY OF THE CASE
PENDING CONDITIONS OF SETTLEMENT
Plaintiff American Airlines, Inc. (“American”) and Defendant Orbitz Worldwide, LLC
hereby file this Joint Motion for Limited Stay of the Case Pending Conditions of Settlement (the
“Joint Motion”). American and Orbitz have entered into a Settlement Agreement dated as of
March 29, 2013 (the “Settlement Agreement”). This Settlement Agreement will have the effect
of resolving all claims asserted between American and Orbitz in this action, subject to the
occurrence of certain events, including (1) the approval of the Settlement Agreement by the
United States Bankruptcy Court for the Southern District of New York in which American, along
with its affiliated debtors, have filed a voluntary petition for relief under chapter 11 of title 11 of
the United States Code, as amended, and (2) such Bankruptcy Court approval becoming final and
no longer subject to review.
American and Orbitz respectfully request that this case be stayed as to American’s claims
against Orbitz pending the conditions as provided in the Settlement Agreement. American and
Orbitz further respectfully request any such additional relief to which they are entitled.

Respectfully submitted,

/s/ Anna Rotman_________________
R. Paul Yetter
State Bar No. 22154200
[e-mail]
Anna Rotman
State Bar No. 24046761
[e-mail]
YETTER COLEMAN LLP
909 Fannin, Suite 3600
Houston, Texas 77010
713.632.8000
713.632.8002 (fax)

/s/ Christopher S. Yates
Christopher S. Yates
[e-mail]
Daniel M. Wall
[e-mail]
Brendan A. McShane
[e-mail]
LATHAM & WATKINS LLP
505 Montgomery Street, Suite 2000
San Francisco, CA 94111-6538
415.391.0600
415.395.8095 (Fax)

Yolanda Cornejo Garcia
State Bar No. 24012457
[e-mail]
Michelle Hartmann
State Bar No. 24032401
[e-mail]
WEIL, GOTSHAL & MANGES LLP
200 Crescent Court, Suite 300
Dallas, Texas 75201-6950
214.746.7700
214.746.7777 (fax)

John J. Little
[e-mail]
LITTLE PEDERSON FANKHAUSER LLP
901 Main Street, Suite 4110
Dallas, TX 75202-3714
214.573.2300
214.573.2323 (Fax)

Bill F. Bogle
State Bar No. 02561000
[e-mail]
Roland K. Johnson
State Bar No. 00000084
[e-mail]
HARRIS, FINLEY & BOGLE, P.C.
777 Main Street, Suite 3600
Fort Worth, Texas 76102
817.870.8700
817.332.6121 (fax)
Attorneys for Plaintiff American Airlines,
Inc.

Attorneys for Defendant Orbitz Worldwide,
LLC

Of Counsel to Plaintiff:
Richard A. Rothman
[e-mail]
James W. Quinn
[e-mail]
WEIL, GOTSHAL & MANGES LLP
767 Fifth Avenue
New York, New York 10153
212.310.8426
212.310.8285 (fax)
M.J. Moltenbrey
[e-mail]
PAUL HASTINGS LLP
875 15th Street, N.W.
Washington, DC 20005
202.551.1725
202.551.0225 (fax)

CERTIFICATE OF SERVICE
I hereby certify that all counsel of record who are deemed to have consented to
electronic service are being served with a copy of the foregoing document via the Court’s
CM/ECF system pursuant to the Court’s Local Rule 5.1(d) this 1st day of April, 2013.
/s/ Anna Rotman______________________
Anna Rotman

CERTIFICATE OF CONFERENCE
On April 1, 2013, I spoke with counsel for Travelport, who indicated that it does
not oppose the relief sought herein.
/s/ Anna Rotman______________________
Anna Rotman