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New Pacer--(Fish) Settlement Agreement
posted on Feb 20, 07 01:26PM
New Pacer--(Fish) Settlement Agreement
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION RUSSELL H. FISH, III and ROBERT §
ANDERSON, as Trustee of the Fish Family Trust, §
Plaintiffs,
v. Civil Action No. 3:06-CV-0815-K
consolidated with
Civil Action No. 3:06-CV-1203-K
PATRIOT SCIENTIFIC CORPORATION, a
Delaware corporation, § ECF
Defendant.
JOINT MOTION TO AMEND SCHEDULE TO EXTEND DEADLINES
Plaintiffs Russell H. Fish, III, Robert Anderson, as trustee of the Fish Family Trust, and Defendant Patriot Scientific Corporation jointly move the Court to amend the current schedule in this case to extend all deadlines by ninety (90) days. After extensive mediation and negotiations, on February 14, 2007, the parties entered into a settlement agreement to resolve the current disputes in this action. As part of that settlement, Patriot Scientific has an obligation to make a payment to the Plaintiffs on or before May 1, 2007. As an additional component of the settlement, in the event Patriot Scientific fails to meet that payment obligation, Patriot Scientific has agreed that Plaintiffs may seek expedited relief in this action in the form of a stipulated judgment. The parties, therefore, request an extension of all deadlines in this action (including Plaintiffs’ expert report deadline) by 90 days to allow Patriot Scientific to fulfill its May 1st payment obligation. Under the requested extension, Plaintiffs will submit a status report to the Court by May 4, 2007 regarding the status of the case, which should, hopefully, be followed quickly by a joint dismissal by all parties. The parties submit that the requested extension is in the interest of justice. For the foregoing reasons, the parties respectfully submit that the requested extension is well-founded
and should be granted.
Respectfully submitted,
MORGAN, LEWIS & BOCKIUS LLP
/s/ Jerry R. Selinger___________
Jerry R. Selinger
State Bar No. 18008250
Susan E. Powley
State Bar No. 00784785
CERTIFICATE OF SERVICE
I hereby certify that on February 20, 2007, I electronically filed the foregoing document with the clerk of court for the U.S. District Court, Northern District of Texas, using the electronic case filing system of the court. The following attorneys of record have consented in writing to accept notice as service of this document by electronic means and are being served by a “Notice of Electronic Filing” sent by the electronic case filing (“ECF”) system.
Steven R. Baggett
THOMPSON & KNIGHT LLP
1700 Pacific Avenue, Suite 3300
Dallas, Texas 75201-4693
Charles T. Hoge
Matthew P. Nugent
KIRBY NOONAN LANCE & HOGE LLP
600 West Broadway. Suite 1100
San Diego, California 92101-3387
Jerry R. Selinger ____
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION RUSSELL H. FISH, III and ROBERT §
ANDERSON, as Trustee of the Fish Family Trust, §
Plaintiffs,
v. Civil Action No. 3:06-CV-0815-K
consolidated with
Civil Action No. 3:06-CV-1203-K
PATRIOT SCIENTIFIC CORPORATION, a
Delaware corporation, § ECF
Defendant.
JOINT MOTION TO AMEND SCHEDULE TO EXTEND DEADLINES
Plaintiffs Russell H. Fish, III, Robert Anderson, as trustee of the Fish Family Trust, and Defendant Patriot Scientific Corporation jointly move the Court to amend the current schedule in this case to extend all deadlines by ninety (90) days. After extensive mediation and negotiations, on February 14, 2007, the parties entered into a settlement agreement to resolve the current disputes in this action. As part of that settlement, Patriot Scientific has an obligation to make a payment to the Plaintiffs on or before May 1, 2007. As an additional component of the settlement, in the event Patriot Scientific fails to meet that payment obligation, Patriot Scientific has agreed that Plaintiffs may seek expedited relief in this action in the form of a stipulated judgment. The parties, therefore, request an extension of all deadlines in this action (including Plaintiffs’ expert report deadline) by 90 days to allow Patriot Scientific to fulfill its May 1st payment obligation. Under the requested extension, Plaintiffs will submit a status report to the Court by May 4, 2007 regarding the status of the case, which should, hopefully, be followed quickly by a joint dismissal by all parties. The parties submit that the requested extension is in the interest of justice. For the foregoing reasons, the parties respectfully submit that the requested extension is well-founded
and should be granted.
Respectfully submitted,
MORGAN, LEWIS & BOCKIUS LLP
/s/ Jerry R. Selinger___________
Jerry R. Selinger
State Bar No. 18008250
Susan E. Powley
State Bar No. 00784785
CERTIFICATE OF SERVICE
I hereby certify that on February 20, 2007, I electronically filed the foregoing document with the clerk of court for the U.S. District Court, Northern District of Texas, using the electronic case filing system of the court. The following attorneys of record have consented in writing to accept notice as service of this document by electronic means and are being served by a “Notice of Electronic Filing” sent by the electronic case filing (“ECF”) system.
Steven R. Baggett
THOMPSON & KNIGHT LLP
1700 Pacific Avenue, Suite 3300
Dallas, Texas 75201-4693
Charles T. Hoge
Matthew P. Nugent
KIRBY NOONAN LANCE & HOGE LLP
600 West Broadway. Suite 1100
San Diego, California 92101-3387
Jerry R. Selinger ____
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