`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`
`
`HOSPIRA, INC.,
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`
`Plaintiff,
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`v.
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`AMNEAL PHARMACEUTICALS LLC,
`
`
`Defendant.
`
`C.A. No. 15-697-RGA
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`AMNEAL'S SUPPLEMENTAL NOTICE OF DEPOSITION OF
`HOSPIRA, INC. PURSUANT TO FED. R. CIV. P. 30(b)(6)
`
`PLEASE TAKE NOTICE that, pursuant to Rule 30(b)(6) of the Federal Rules of Civil
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`
`
`
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`Procedure, Defendant Amneal Pharmaceuticals LLC (“Amneal”) by its attorneys, will take the
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`deposition upon oral examination of Plaintiff Hospira, Inc. (“Hospira”), before a court reporter,
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`notary public, or other person authorized by law to administer oaths and take testimony. The
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`deposition will commence at 9:00 AM EST on December 16, 2016, at the offices of Sughrue
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`Mion, PLLC, 2100 Pennsylvania Avenue, NW, Washington, DC 20037, or such other date, time,
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`and location as may be mutually agreed to by counsel. The deposition will be recorded by
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`stenographic means and will be videotaped. You are invited to attend and participate.
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`
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`PLEASE TAKE FURTHER NOTE that, pursuant to Rule 30(b)(6), Hospira is required to
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`designate and produce one or more knowledgeable person to testify on its behalf with respect to
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`the matters set forth in Schedule A, attached hereto. The person(s) so designated shall be
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`required to testify as to those matters known or reasonably available to Hospira. Amneal
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`requests that Hospira identify in writing at least ten (10) business days in advance of the
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`
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`Case 1:15-cv-00697-RGA Document 76 Filed 11/28/16 Page 2 of 4 PageID #: 936
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`deposition, the name(s) and title(s) of the person(s) who will testify on its behalf and the subject
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`matters on which each person will testify. You are invited to attend and cross-examine.
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`
`
`
`
`/s/ Christine D. Haynes
`Kelly E. Farnan (#4395)
`Christine D. Haynes (#4697)
`Richards, Layton & Finger, P.A.
`920 North King Street
`Wilmington, DE 19801
`(302) 651-7700
`farnan@rlf.com
`haynes@rlf.com
`
`Attorneys for Defendant-Counterclaim Plaintiff
`Amneal Pharmaceuticals LLC
`
`
`2
`
`
`
`Of Counsel:
`Michael R. Dzwonczyk
`Azy S. Kokabi
`Grant S. Shackelford
`Sughrue Mion, PLLC
`2100 Pennsylvania Ave., NW
`Washington, DC 20037
`(202) 293-7060
`
`Dated: November 28, 2016
`
`
`
`
`
`
`
`
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`Case 1:15-cv-00697-RGA Document 76 Filed 11/28/16 Page 3 of 4 PageID #: 937
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`
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`DEFINITIONS
`
`
`The definitions set forth in “AMNEAL'S NOTICE OF DEPOSITION OF HOSPIRA,
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`INC. PURSUANT TO FED. R. CIV. P. 30(b)(6),” served August 31, 2016, are incorporated
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`herein by reference into this document as if set forth in their entirety. Notwithstanding any
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`applicable Definition, each word, term, or phrase used in these interrogatories is intended to have
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`the broadest meaning permitted under the Federal Rules of Civil Procedure.
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`
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`3
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`
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`Case 1:15-cv-00697-RGA Document 76 Filed 11/28/16 Page 4 of 4 PageID #: 938
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`
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`SCHEDULE A
`SUPPLEMENTAL DEPOSITION TOPICS
`
`37.
`Hospira’s knowledge of products containing dexmedetomidine for veterinary use
`sold within the United States, including Dexdomitor®.
`
`
`
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`4
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