American Airlines Inc v. Travelport Limited et al

Filing 479

Agreed MOTION to Dismiss with Prejudice filed by American Airlines Inc (Attachments: #1 Proposed Order) (Garcia, Yolanda)

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

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

AGREED MOTION TO DISMISS WITH PREJUDICE
Pursuant to Rule 41(a)(2) of the Federal Rules of Civil Procedure, Plaintiff American
Airlines, Inc. (“American”) and Defendant Orbitz Worldwide, LLC (“Orbitz”) move this Court
to enter the attached agreed proposed order dismissing with prejudice American’s claims against
Orbitz. American and Orbitz have fully resolved and settled for mutual valuable consideration
all disputes in this matter as between them, and such settlement has been approved by the United
States Bankruptcy Court for the Southern District of New York. Accordingly, no issues remain
between American and Orbitz that require judicial resolution, and Orbitz should be dismissed
from this litigation with prejudice.
REQUESTED RELIEF
American and Orbitz respectfully request that the Court grant this Agreed Motion to
Dismiss with Prejudice and enter the proposed Order attached hereto as Exhibit A. American
and Orbitz further request that the Court grant them any further relief to which they may be
justly entitled.

C:\DESKTOP\AGREED MOTION TO DISMISS ORBITZ.DOCX

Respectfully submitted,

/s/ Yolanda Cornejo Garcia
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)

/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)

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)

John J. Little
[e-mail]
LITTLE PEDERSEN FANKHAUSER LLP
901 Main Street, Suite 4110
Dallas, TX 75202-3714
214.573.2300
214.573.2323 (Fax)
Attorneys for Defendant Orbitz Worldwide,
LLC

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

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C:\DESKTOP\AGREED MOTION TO DISMISS ORBITZ.DOCX

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 9th day of May, 2013.

/s/ Yolanda Cornejo Garcia
Yolanda Cornejo Garcia

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C:\DESKTOP\AGREED MOTION TO DISMISS ORBITZ.DOCX