Kenneth D. Friedman, Esq. 

MANATT, PHELPS & PHILLIPS, LLP 

7 Times Square 

New York, New York 10036 

Telephone: (212) 790-4500 

Attorneys for Defendants 

Paging Systems, Inc. and Touch Tel Corporation 

UNITED STATES DISTRICT COURT 

DISTRICT OF NEW JERSEY 

WARREN HAVENS, SKYBRIDGE 

SPECTRUM FOUNDATION, a Delaware 

nonprofit corporation; TELESAURUS VPC, 

LLC, a Delaware limited liability company; 

AMTS CONSORTIUM, LLC, a Delaware 

Limited Liability Company; INTELLIGENT 

TRANSPORTATION & MONITORING, LLC, 

a Delaware Limited Liability Company; and 

TELESAURUS GB, LLC, a Delaware Limited 

Liability Company, 

Plaintiffs, 

v. 

MOBEX NETWORK SERVICES, LLC, a 

Delaware Limited Liability Company; MOBEX 

COMMUNICATIONS, INC., a Delaware 

corporation; MARITIME 

COMMUNICATIONS/LAND MOBILE, LLC, 

a Delaware Limited Liability Company; 

PAGING SYSTEMS, INC., a California 

Corporation; TOUCH TEL CORPORATION, a 

California corporation; and JOHN DOE Nos. 1-

20, 

Defendants. 

Civil Action No. 2:11-CV-00993-KSH-CW 

[PROPOSED] ORDER GRANTING 

MOTION OF DEFENDANTS 

PAGING SYSTEMS, INC. AND 

TOUCH TEL CORPORATION 

TO ENFORCE SETTLEMENT 

AGREEMENT AND FOR 

DISMISSAL WITH PREJUDICE 

PURSUANT TO RULE 41(b) 

THIS MATTER having been opened to the Court upon the motion of defendants Paging 

Systems, Inc. and Touch Tel Corporation (collectively, the “Paging Systems Defendants”) for an 

order granting the Paging Systems Defendants’ Motion to Enforce Settlement Agreement and 

For Dismissal with Prejudice Pursuant to Rule 41(b), and proper notice having been given to 

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-2- 

counsel for Plaintiffs, and the Court having considered the written submission of the parties, and 

any oral argument of counsel, and good cause having been shown; 

IT IS, on this ______ day of ___________________, 2014, 

ORDERED that the Paging Systems Defendants’ Motion to Enforce Settlement 

Agreement and For Dismissal with Prejudice Pursuant to Rule 41(b) is hereby GRANTED; 

IT IS FURTHER ORDERED that Plaintiffs shall promptly comply with all of their 

outstanding obligations under the settlement agreement made and entered into April 8, 2013 

(“Settlement Agreement”), by and between Plaintiffs and the Paging Systems Defendants 

including, but not limited to, (i) executing and delivering, via email, the Officer’s Certificates 

and Assignment and Assumptions Agreements memorializing the assignments of geographic 

AMTS license effected by numbered paragraphs 2 and 3 of the Settlement Agreement, (ii) filing 

all required notices of consummation of assignment with the FCC, and (iii) causing Plaintiffs’ 

counsel of record to execute and deliver, via email, a stipulation, in the form agreed to by the 

parties, dismissing the Paging Systems Defendants from this action with prejudice. 

IT IS FURTHER ORDERED that Plaintiffs failure to deliver the executed closing 

documents identified above, and the executed stipulation of dismissal, to counsel for the Paging 

Systems Defendants within seven (7) days of the date of this Order shall result in the dismissal of 

this action against the Paging Systems Defendants, with prejudice, pursuant to Rule 41(b) of the 

Federal Rules of Civil Procedure 

_________________________________ 

Honorable Katherine S. Hayden, U.S.D.J. 

311629362.1 

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