Defendants. JOINT MOTION TO STAY PROCEEDINGS Plaintiff IGEN International, Inc. ("IGEN") and Defendants Roche Diagnostics Corp. ("RDC") and Roche Diagnostics GmbH, ("RDG") pursuant to an agreement between the parties, jointly move for a stay of proceedings. Since the complaint was filed on July 9, 2003, the parties have executed a series of agreements including an Agreement and Plan of Merger dated as of July 24, 2003 ("Merger Agreement") among IGEN, IGEN Integrated Healthcare, LLC, Roche Holding Ltd, 66 Acquisition Corporation II (an affiliate of Roche Holding Ltd) under which, among other things, an affiliate of RDG and RDC will merge with and into IGEN. Contemporaneously with the execution of the Merger Agreement, the parties executed and delivered certain other agreements including an Ongoing Litigation Agreement. Under that agreement, the parties agreed that it was in their best interest, among other things, to jointly file this motion and to take such further actions as may be reasonably necessary, appropriate, desirable, or required in order to facilitate the court entering and maintaining the order contemplated by this motion. Under the terms of the Ongoing Litigation Agreement, the parties agreed that the proceedings in this case, including the running of the time for serving the complaint upon Roche Diagnostics GmbH, are to be stayed until the earlier to occur of the termination or expiration of the Merger Agreement or consummation of the closing of merger as contemplated by the Merger Agreement. The parties agree that if the merger is not consummated, this stay will not prejudice IGEN's right to seek a preliminary injunction in this proceeding and agree that the stay shall not affect, and that Roche will not assert that the stay has affected, IGEN's contention that Roche's alleged infringement of the patents in suit is causing irreparable harm to IGEN. A proposed order consistent with this motion is attached. Respectfully submitted, Dated: ____________________ _____________________________________ Donald R. Dunner Thomas H. Xxxxxxx Gerald F. Xxxx, Xxx Xx. 03412 Xxxxxxxx X. Mason, Bar No. 15772 Xxxxxxx X. Strauss, Bar No. 15775 XXXXXXXX, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. 1300 I Street, N.W. Washinxxxx, X.X. 00000-0000 (000) 000-0000 Attorneys xxx Xxxxxxxxx IGEN International, Inc. Dated: ____________________ _____________________________________ [Attorney Name] [Firm Name] [Address] Attorneys for Defendants Roche Diagnostics Corp., et al. IN THE U...
Defendants. “Defendants” means Xxxx X. XXXX, Acting Secretary of Homeland Security, in his official capacity; Xxxxxxx XXXX, Attorney General of the United States, in his official capacity; Xxxxxxx X. XXXXXXX, Deputy Director for ICE (Senior Official Performing the Duties of the Director, ICE), in his official capacity; Xxxxxxx X. XXXXXXXXXX, Senior Official Performing the Duties of the Director, USCIS, in his official capacity; Xxxx X. XXXXXX, Acting Commissioner of CBP, in his official capacity; and Xxxxx XXXXXXX, Director of EOIR, in his official capacity.
Defendants. Defendants" are Xxxxxx Xxxxxx, in his capacity as Commissioner of the Department of Mental Health and Mental Retardation; the Department of Mental Health and Mental Retardation; Xxxxx Xxxxxxx, Superintendent of the Augusta Mental Health Institute; X. Xxxxxx Xxxx, Commissioner of the Maine Department of Human Services; Maine Department of Human Services; and their successors and assigns.
Defendants a) Have developed and are using cross-system protocols or allied system agreements to coordinate services and participate in CFTs for Class members, consistent with a Memoranda of Understanding between DSHS administrations and HCA;
Defendants a) Received court approval of its Implementation Plan, as described in paragraphs 55-58; and
Defendants a) Developed and are using a Quality Assurance Plan;
Defendants. “Defendants” shall mean Xxx Xxxxxxx, Secretary of the Interior, Xxxxx Xxxxxxxx, Assistant Secretary of the Interior – Indian Affairs, and X. Xxxxxxx Xxxxxxxx, Secretary of the Treasury, and their successors in office, all in their official capacities.
Defendants the officers charged with carrying out the trust obligations of the United States, and their predecessors, have grossly mismanaged, and continue grossly to mismanage, such trusts and trust assets in at least the following respects, among others:
Defendants. The parties in the above-captioned action have reached a settlement of their disputes and desire to conclude the litigation. Therefore, the parties stipulate that the Court may enter an Order dismissing this action in its entirety with prejudice. A proposed Order accompanies this Stipulation. Cxxxx Kxxxxxx Dxxx & Qxxxxxx RESPECTFULLY SUBMITTED this ___ day of April, 2014.
Defendants. XXXXX X. XXXXXX, IN HIS CAPACITY AS COURT-APPOINTED RECEIVER FOR THE STANFORD RECEIVERSHIP ESTATE, AND THE OFFICIAL STANFORD INVESTORS COMMITTEE, Plaintiffs, - against - PROSKAUER ROSE, LLP, et al.,
