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Case 1:15-cv-00697-RGA Document 34 Filed 12/23/15 Page 1 of 3 PageID #: 216
`Case 1:15-cv-00697-RGA Document 34 Filed 12/23/15 Page 1 of 3 PagelD #: 216
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF DELAWARE
`
`HOSPIRA, INC,
`
`V.
`
`Plaintiff,
`
`AMNEAL PHARMACEUTICALS LLC,
`
`Defendant.
`
`Civil Action No. 15-697—RGA
`
`STIPULATION AND |PROPOSED| AMENDED SCHEDULING ORDER
`
`IT IS HEREBY STIPULATED by and between Plaintiff Hospira, Inc., and Defendant
`
`Amneal Pharmaceuticals LLC, subject to the approval by the Court as follows:
`
`1.
`
`The case scheduling order (D1. 13; and as amended at D.I. 16, 19, 21, 28, 29, and
`
`30) shall be amended as follows:
`
`New Deadline
`
`Event
`
`Current Deadline
`
`
`
`11 8 Exchange Terms for Claim
`Construction
`
`' January 6, 2016
`
`January 6, 2016
`
`January 20, 2016
`
`11 8 Exchange Proposed Claim
`Constructions
`
`- January 29, 2016
`
`fl 8 File Joint Claim
`Construction Chart
`
`
`January 15,2016
`
` January 20, 2016
`
`
`
`
`
`
`
`I ll 9 Plaintiff’s Opening Claim
`Construction Brief
`
`
`February 5, 2016
`
`February 12, 2016
`
`March 1, 2016
`
`March 8, 2016
`
` March 29, 2016
`
`11 9 Plaintiffs Reply Claim
`Construction Brief
`
`11 9 Defendant’s Answering
`Claim Construction Brief
`
`' March 22,2016
`
`

`

`Case 1:15-cv-00697-RGA Document 34 Filed 12/23/15 Page 2 of 3 PageID #: 217
`Case 1:15-cv-00697-RGA Document 34 Filed 12/23/15 Page 2 of 3 PagelD #: 217
`
`
`1t 9 Defendant’s Sur-Reply
`‘1 April 5, 2016
`' April 12,2016
`Claim Construction Brief
`
`1i 9 File Joint Claim
`April 12, 2016
`April 15, 2016
`Construction Brief
`
`
`
`
`2.
`
`Pursuant to paragraph 4 of the Default Standard for Discovery, the Plaintiff’ s
`
`identification of asserted claims and its initial claim chart relating each accused product to
`
`asserted claims each product allegedly infringes, which are currently due December 23, 2015,
`
`shall be due January 8, 2016, and Defendant’s initial invalidity contentions, which are currently
`
`due January 22, 2016, shall be due February 5, 2016.
`
`3.
`
`Plaintiff’ s responses and objections to Defendant’s first set of interrogatories and
`
`requests for production, which are currently due January 20, 2016, shall be due February 3, 2016.
`
`4.
`
`All other dates in effect under the Default Standard for Discovery and the case
`
`schedule (DI. 13; and as amended at DJ. 16, 19, 21, 28, 29, and 30) shall remain the same and
`
`the extension of the specific dates of this stipulation shall not be a basis for seeking extension of
`
`such other dates.
`
`

`

`Case 1:15-cv-00697-RGA Document 34 Filed 12/23/15 Page 3 of 3 PageID #: 218
`Case 1:15-cv-00697-RGA Document 34 Filed 12/23/15 Page 3 of 3 PagelD #: 218
`
`CONNOLLY GALLAGHER LLP
`
`RICHARDS, LAYTON & FINGER, P.A.
`
`
`/s/ RM P. Newell
`Arthur G. Connolly, III (#2667)
`Ryan P. Newell (#4744)
`The Brandywine Building
`1000 West Street
`Wilmington, DE 19801
`(302) 757—7300
`aconnol1y@connollygallagher.com
`rnewell@connollygallagher.com
`
`
`/s/ Kelly E. Farnan
`Kelly E. Farnan (#4395)
`Christine D. Haynes (#4697)
`One Rodney Square
`920 North King Street
`Wilmington, DE 19801
`(302) 651-7700
`farnan@rlf.com
`haynes@r1f.com
`
`Attorneysfor Plaintifi’Hospira, Inc.
`
`Attorneysfor Defendant-Counterclaim Plaintifi’
`Amneal Pharmaceuticals LLC
`
`OF COUNSEL:
`
`OF COUNSEL:
`
`Michael R. Dzwonczyk
`Bradford P. Lyerla
`Renita S. Rathinam
`Sara T. Horton
`Alton Hare
`Yusuf Esat
`SUGHRUE MION, PLLC
`Michael T. Werner
`2100 Pennsylvania Ave, NW
`JENNER & BLOCK LLP
`353 N. Clark Street Chicago, IL 60654-3456 Washington, DC 20037
`Telephone: 312 222-9350
`(202) 293-7060
`Facsimile: 312 527-0484
`mdzwonczyk@sughrue.com
`B1yer1a@j enner.com
`rrathinam@sughrue.com
`shorton@j enner.com
`ahare@sughrue.com
`yesat@j enner.com
`mwerner@j enner.com
`
`Dated: December 23, 2015
`
`SO ORDERED this
`
`_ day of December, 2015.
`
`
`
`THE HONORABLE RICHARD G. ANDREWS
`
`UNITED STATES DISTRICT JUDGE
`
`

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