Penovia LLC v. Acer America CorporationMOTION to Stay PENDING SETTLEMENTE.D. Tex.June 3, 2014 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PENOVIA, LLC, Plaintiff, v. Civil Action No. 2:14-cv-237 JURY TRIAL DEMANDED SONY ELECTRONICS INC., Defendant, PARTIES’ JOINT MOTION TO STAY PENDING SETTLEMENT PAPERS Plaintiff Penovia, LLC (“Penovia”) and Defendant Sony Electronics Inc. (“Sony”) hereby submit this Joint Motion to Stay Pending Settlement Papers in the present case in view of the parties’ agreement on terms for settlement. At this time, Penovia and Sony have reached terms of settlement and are in the process of finalizing the settlement papers. In light of the forthcoming settlement, and the subsequent dismissal of this action, Penovia and Sony submit that judicial resources would best be served by a temporary stay of any further proceedings for forty five (45) days, while the parties finalize their formal agreements. For the foregoing reasons, Penovia and Sony request that the Court grant this joint motion and enter a temporary stay of all further proceedings in the case between Penovia and Sony for forty-five (45) days, until July 18, 2014. A proposed order granting this motion is filed concurrently herewith for the Court’s convenience. - 2 - Dated: June 3, 2014 Respectfully submitted, By: /s/Andrew W. Spangler Andrew W. Spangler State Bar. No. 24041960 Spangler Law P.C. 208 N. Green Street, Suite 300 Longview, Texas 75601 Telephone: (903) 753-9300 Facsimile: (903) 553-0403 Email: spangler@spanglerlawpc.com Stamatios Stamoulis DE SB No. 4606 stamoulis@swdelaw.com Richard C. Weinblatt DE SB No. 5080 weinblatt@swdelaw.com Stamoulis & Weinblatt LLC Two Fox Point Centre 6 Denny Road, Suite 307 Wilmington, DE 19809 Telephone: (302) 999-1540 Facsimile: (302) 762-1688 ATTORNEYS FOR PLAINTIFF PENOVIA LLC By: /s/ Deron R. Dacus Deron R. Dacus State Bar No. 00790553 The Dacus Firm, P.C. 821 ESE Loop 323 Suite 430 Tyler, TX 75701 Telephone: (903) 705-1117 Facsimile: (903) 705-1117 ddacus@dacusfirm.com ATTORNEY FOR DEFENDANT SONY ELECTRONICS INC. - 3 - CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this notice was served on all counsel who are deemed to have consented to electronic service. Local Rule CV-(5)(a)(3)(A). Pursuant to Fed. R. Civ. P. 5(d) and Local Rule CV-5(d), all other counsel of record not deemed to have consented to electronic service were served with a true and correct copy of the foregoing by email and/or fax, on this 3 rd day of June, 2014. /s/Andrew W. Spangler Andrew W. Spangler