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UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION
3M COMPANY
Plaintiff,
CASE NO. 8:20-cv-1003-T-35CPT
v.
TAC2 GLOBAL LLC
Defendant.
/
JOINT MOTION TO CONTINUE HEARING ON PLAINTIFF’S
MOTION FOR PRELIMINARY INJUNCTION
Defendant, TAC2 GLOBAL, LLC (“TAC2” or “Defendant”) and Plaintiff, 3M
COMPANY (“3M” or “Plaintiff”), (collectively, ”The Parties”), pursuant to M.D. Fla. Local Rule
3.09, by and through their undersigned counsel, hereby move to continue the hearing on Plaintiff’s
Motion for Preliminary Injunction for a minimum of fourteen (14) days and in support thereof,
state as follows:
1.
This is action consists of an eight-count Complaint asserting various causes of
action related to trademark infringement under federal and state law.
2.
Plaintiff served its Motion for Temporary Restraining Order and Preliminary
Injunction and Supporting Memorandum of Law on May 8, 2020.
3.
A hearing on Plaintiff’s Motion for Temporary Restraining Order was held on May
12, 2020. [D.E. 15].
4.
The Court entered an order on Plaintiff’s Motion for Temporary Restraining Order
(“TRO”) that was to remain in effect until June 3, 2020, on which date the Court will hear
Plaintiff’s Motion for Preliminary Injunction. [D.E. 25].
5.
The Parties are engaged in meaningful settlement negotiations to either resolve the
entire Complaint or, alternatively, to resolve the preliminary injunction motion without the
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expense of a hearing. The parties agree that it is in their best interest to continue the hearing on
Plaintiff’s Motion for Preliminary Injunction scheduled for June 3, 2020 for at least fourteen (14)
days while the parties attempt to come to a resolution.
6.
Thus, The Parties request that the hearing on Plaintiff’s Motion for Preliminary
Injunction be heard on June 17, 2020, or as soon thereafter as the Court is available.
7.
The Parties stipulate that the TRO will be extended until and through the new
hearing date.
MEMORANDUM OF LAW
M.D. Fla. Local Rule 3.09 provides that the Court may continue a hearing for good cause.
As stated above, The Parties have provided good cause to continue the hearing on Plaintiff’s
Motion for Preliminary Injunction due to the ongoing settlement negotiations between The Parties.
There will be no prejudice to the Court or The Parties if the Joint Motion to granted.
WHEREFORE, The Parties’ counsel respectfully request that this Court grant this Joint
Motion to Continue Hearing on Plaintiff’s Motion for Preliminary Injunction until June 17, 2020,
or as soon thereafter as the Court will allow and extend the TRO until and through the new hearing
date, and for any other relief the Court deems appropriate.
Dated this 1st day of June, 2020.
/s/ Amy E. Stoll________________
Amy E. Stoll, Esquire
Florida Bar No. 150959
Richard C. Alvarez, Esquire
Florida Bar No. 031615
OLDER LUNDY & ALVAREZ
1000 West Cass Street
Tampa, Florida 33606
T: 813-254-8998
triallawyers@olalaw.com
astoll@olalaw.com
Counsel to Defendant
/s/ Joseph M. Wasserkrug_______
Joseph M. Wasserkrug
Florida Bar No. 112274
333 SE 2nd Avenue, Suite 4500
Miami Florida, 33131-4336
T: 305-347-6501
jwasserkrug@mwe.com
Michael W. Weaver
Illinois Bar No. 6291021
444 W. Lake Street, Suite 4000
Chicago, IL 60606-0029
T: 312-984-5820
mweaver@mwe.com
Counsel for Plaintiffs
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