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1. IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION
CRYPTOPEAK SOLUTIONS, LLC,
Plaintiff,
v.
SCOTTRADE, INC.,
Defendant.
Case No. 2:15-cv-1312
PATENT CASE
JURY TRIAL DEMANDED
JOINT MOTION TO STAY ALL DEADLINES AND NOTICE OF SETTLEMENT
BETWEEN PLAINTIFF CRYPTOPEAK AND DEFENDANT SCOTTRADE, INC.
Plaintiff CryptoPeak Solutions, LLC (“CryptoPeak”), and Defendant Scottrade, Inc.
(“Scottrade”) hereby file this Joint Motion to Stay All Deadlines and Notice of Settlement, and in
support thereof respectfully show the Court as follows:
All matters in controversy between CryptoPeak and Scottrade have been settled, in
principle. The parties are in the process of finalizing the terms of a written settlement agreement.
The parties wish to conclude the settlement without burdening the Court with any additional filings
and without incurring unnecessary expense. The parties anticipate that they will be able to finalize
the written settlement agreement and submit dismissal papers within approximately 30 days.
Accordingly, CryptoPeak and Scottrade jointly and respectfully request that the Court grant a stay
of the proceedings between them, including all deadlines, until October 30, 2015.
The parties submit that good cause exists for granting this agreed motion, as set forth above.
This motion is not filed for purposes of delay, but so that justice may be served.
A proposed order granting this Joint Motion is attached.
Wherefore, CryptoPeak and Scottrade respectfully request that the Court enter the
proposed order submitted with this Motion as set forth above, and grant the parties such other and
further relief to which they are entitled.
Case 2:15-cv-01312-RWS-RSP Document 12 Filed 09/30/15 Page 1 of 3 PageID #: 45
2. 2
Dated: September 30, 2015 Respectfully submitted,
/s/ Craig Tadlock
Craig Tadlock
State Bar No. 00791766
John J. Harvey, Jr.
State Bar No. 09179770
Keith Smiley
State Bar No. 24067869
TADLOCK LAW FIRM PLLC
2701 Dallas Parkway, Suite 360
Plano, Texas 75093
903-730-6789
craig@tadlocklawfirm.com
john@tadlocklawfirm.com
keith@tadlocklawfirm.com
Attorneys for Plaintiff CryptoPeak Solutions, LLC
/s/ Jason M. Schwent
Jason M. Schwent
Alan H. Norman
THOMPSON COBURN LLP
One US Bank Plaza
S. Louis, Missouri 63101
314-552-6291
jschwent@thompsoncoburn.com
anorman@thomopsoncoburn.com
Attorneys for Defendant Scottrade, Inc.
Case 2:15-cv-01312-RWS-RSP Document 12 Filed 09/30/15 Page 2 of 3 PageID #: 46
3. 3
CERTIFICATE OF CONFERENCE
The undersigned certifies that on September 30, 2015, counsel for Plaintiff conferred with
counsel for Defendant, and the parties agree to the form and substance of this motion.
/s/ Craig Tadlock
Craig Tadlock
CERTIFICATE OF SERVICE
I hereby certify that all counsel of record who have consented to electronic service are
being served with a copy of this document via the Court’s CM/ECF system per Local Rule CV-
5(a)(3) on September 30, 2015.
/s/ Craig Tadlock
Craig Tadlock
Case 2:15-cv-01312-RWS-RSP Document 12 Filed 09/30/15 Page 3 of 3 PageID #: 47
4. IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION
CRYPTOPEAK SOLUTIONS, LLC,
Plaintiff,
v.
SCOTTRADE, INC.,
Defendant.
Case No. 2:15-cv-1312
PATENT CASE
JURY TRIAL DEMANDED
ORDER GRANTING JOINT MOTION TO STAY ALL DEADLINES
BETWEEN PLAINTIFF CRYPTOPEAK AND DEFENDANT SCOTTRADE, INC.
On this date the Court considered the Joint Motion to Stay Proceedings and Notice of
Settlement, filed jointly by Plaintiff CryptoPeak Solutions, LLC (“CryptoPeak”), and Defendant
Scottrade, Inc. (“Scottrade”). Based on the motion, the grounds set forth therein, the pleadings
and other filings in this case, and the agreement of the parties to the motion, the Court finds that
good cause has been established and the Joint Motion to Stay should be GRANTED.
It is therefore ORDERED that all proceedings between CryptoPeak and Scottrade,
including all pending deadlines, are hereby stayed until October 30, 2015.
Case 2:15-cv-01312-RWS-RSP Document 12-1 Filed 09/30/15 Page 1 of 1 PageID #: 48