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Case 1:15-cv-00264-GMS Document 19 Filed 12/07/15 Page 1 of 4 PageID #: 150
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 15-264 (GMS)
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`))))))))))
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`HELSINN HEALTHCARE S.A. and
`ROCHE PALO ALTO LLC,
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`Plaintiffs,
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`v.
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`HOSPIRA, INC.,
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`Defendant.
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`PLAINTIFFS’ MOTION TO STAY THE SECOND-FILED
`CASE IN THE DISTRICT OF DELAWARE
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`Plaintiffs Helsinn Healthcare S.A. and Roche Palo Alto LLC (collectively,
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`“Plaintiffs”) move to stay this second-filed action pending resolution of a motion to dismiss
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`Plaintiffs’ amended complaint filed by Hospira in the first-filed New Jersey action. The grounds
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`for this motion are set forth in Plaintiffs’ Opening Brief submitted herewith.
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`MORRIS, NICHOLS, ARSHT & TUNNELL LLP
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`/s/ Karen Jacobs
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`
`
`Jack B. Blumenfeld (#1014)
`Karen Jacobs (#2881)
`Maryellen Noreika (#3208)
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19899
`(302) 658-9200
`jblumenfeld@mnat.com
`kjacobs@mnat.com
`mnoreika@mnat.com
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`Attorneys for Plaintiffs
`Helsinn Healthcare S.A. and
`Roche Palo Alto LLC
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`
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`OF COUNSEL:
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`Joseph M. O’Malley, Jr.
`Eric W. Dittmann
`Young J. Park
`Isaac S. Ashkenazi
`Gary Ji
`Angela C. Ni
`Dana Weir
`PAUL HASTINGS LLP
`75 East 55th Street
`New York, NY 10022
`(212) 318-6000
`
`Attorneys for Plaintiff
`Helsinn Healthcare S.A
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`
`

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`Case 1:15-cv-00264-GMS Document 19 Filed 12/07/15 Page 2 of 4 PageID #: 151
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`2
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`Mark E. Waddell
`LOEB & LOEB LLP
`345 Park Avenue
`New York, NY 10154
`(212) 407-4127
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`Attorneys for Plaintiff
`Roche Palo Alto LLC
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`December 7, 2015
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`
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`

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`Case 1:15-cv-00264-GMS Document 19 Filed 12/07/15 Page 3 of 4 PageID #: 152
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`RULE 7.1.1 CERTIFICATE
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`I hereby certify that the subject of the foregoing motion has been discussed with
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`counsel for the defendant and that we have not been able to reach agreement.
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`/s/ Karen Jacobs
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`Karen Jacobs (#2881)
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`Case 1:15-cv-00264-GMS Document 19 Filed 12/07/15 Page 4 of 4 PageID #: 153
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`CERTIFICATE OF SERVICE
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`I hereby certify that on December 7, 2015, I caused the foregoing to be
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`electronically filed with the Clerk of the Court using CM/ECF, which will send notification of
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`such filing to all registered participants.
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`I further certify that I caused copies of the foregoing document to be served on
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`December 7, 2015, upon the following in the manner indicated:
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`Dominick T. Gattuso, Esquire
`PROCTOR HEYMAN ENERIO LLP
`300 Delaware Avenue, Suite 200
`Wilmington, DE 19801
`Attorneys for Defendant Hospira, Inc.
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`Sara T. Horton, Esquire
`JENNER & BLOCK LLP
`353 North Clark Street
`Chicago, IL 60654-3456
`Attorneys for Defendant Hospira, Inc.
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`VIA ELECTRONIC MAIL
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`VIA ELECTRONIC MAIL
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`/s/ Karen Jacobs
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`Karen Jacobs (#2881)

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