Case 1:15-cv-00697-RGA Document 99 Filed 08/14/17 Page 1 of 17 PageID #: 1262
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`Civil Action No. 15-697-RGA
`
`PUBLIC VERSION:
`Filed August 14, 2017
`
`))))))))))
`
`HOSPIRA, INC.,
`
`v.
`
`Plaintiff,
`
`AMNEAL PHARMACEUTICALS LLC,
`
`Defendant.
`
`PROPOSED JOINT PRE-TRIAL ORDER
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`

`

`Case 1:15-cv-00697-RGA Document 99 Filed 08/14/17 Page 2 of 17 PageID #: 1263
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`TABLE OF CONTENTS
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`I.
`
`INTRODUCTION ...............................................................................................................1
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`A.
`
`B.
`
`Nature of the Action................................................................................................ 1
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`Jurisdiction .............................................................................................................. 3
`
`II.
`
`FACTS .................................................................................................................................4
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`B.
`
`Disputed Facts ......................................................................................................... 4
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`III.
`
`IV.
`
`V.
`
`VI.
`
`ISSUES OF LAW ................................................................................................................4
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`TRIAL EXHIBITS...............................................................................................................5
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`WITNESS LISTS.................................................................................................................9
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`DEPOSITION DESIGNATIONS ......................................................................................10
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`VII.
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`ITEMIZED LIST OF SPECIAL DAMAGES ...................................................................12
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`VIII. STATEMENTS OF INTENDED PROOFS ......................................................................12
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`IX.
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`X.
`
`DESIRED AMENDMENTS TO THE PLEADINGS .......................................................12
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`CERTIFICATION OF ATTEMPTED RESOLUTION OF CONTROVERSY ................12
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`XII.
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`TRIAL PARAMETERS ....................................................................................................12
`
`i
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`

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`Index of terms
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`Term / abbreviation
`RTU
`
`Meaning
`Ready-to-use
`
`mL
`µg/mL
`
`NMT
`
`NDA
`
`ANDA
`
`FDA
`
`Precedex Concentrate
`
`Precedex Premix or RTU Precedex
`
`milliliter
`Microgram (10-6 gram) per milliliter
`
`No more than
`
`New Drug Application
`
`Abbreviated New Drug Application
`
`Food and Drug Administration
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`Hospira’s 100 µg/mL dexmedetomidine in
`2 mL vial product approved by FDA in
`1999.
`
`4 µg/mL dexmedetomidine product sold
`by Hospira in 20 mL, 50 mL, and 100 mL
`vials since 2013.
`
`ii
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`

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`
`I.
`
`INTRODUCTION
`
`1.
`
`Pursuant to the Court’s Scheduling Order (D.I. 13 ¶ 14) and Oral Order (D.I. 94),
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`Plaintiff Hospira, Inc. (“Hospira”) and Defendant Amneal Pharmaceuticals LLC (“Amneal”)
`
`submit this Proposed Joint Pre-Trial Order.
`
`2.
`
`This Order shall control the subsequent course of the action, unless modified by
`
`the Court to prevent manifest injustice.
`
`A.
`
`3.
`
`Nature of the Action
`
`This is a civil action for patent infringement under the patent laws (Title 35 of the
`
`United States Code) and the Hatch-Waxman Act pertaining to generic pharmaceuticals. See 35
`
`U.S.C. § 101 et seq.; 21 U.S.C. § 355.
`
`4.
`
`The action arises from Amneal’s submission of Abbreviated New Drug
`
`Application (“ANDA”) No. 207551 to the United States Food and Drug Administration (“FDA”)
`
`seeking approval to engage in the commercial manufacture, importation, use or sale of 4 µg/mL
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`dexmedetomidine drug products in 50 mL and 100 mL glass vials (“Amneal ANDA Products”)
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`prior to the expiration of Hospira’s U.S. Patent Nos. 8,242,158 (“the ‘158 patent”); 8,338,470
`
`(“the ‘470 patent”); 8,455,527 (“the ‘527 patent”); and 8,648,106 (“the ‘106 patent”)
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`(collectively, the “Patents-in-Suit”).
`
`5.
`
`The four Patents-in-Suit share a common specification and are part of the same
`
`patent family. The application leading to the ‘158 patent was the first application in the family to
`
`be filed, and was filed on January 4, 2012. The inventors listed on each Patent-in-Suit are
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`Priyanka Roychowdhury and Robert A. Cedergren. Neither named inventor is currently
`
`employed by Hospira.
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`6.
`
`Hospira markets its dexmedetomidine products under the trade name PrecedexTM.
`
`Since 1999, Hospira has sold 100 µg/mL dexmedetomidine, which is diluted to 4 µg/mL prior to
`
`
`
`1
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`

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`administration to a patient, in 2 mL glass containers. Since 2013, Hospira has also sold 4 µg/mL
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`dexmedetomidine in 20 mL, 50 mL, and 100 mL glass containers. In this litigation, the parties
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`refer to the 100 µg/mL Precedex product as Precedex Concentrate and to the 4 µg/mL Precedex
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`products as Precedex Premix or RTU Precedex.
`
`7.
`
`Dexmedetomidine is used as a sedative. Precedex is indicated for (1) sedation of
`
`initially intubated and mechanically ventilated patients during treatment in an intensive care
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`setting, and (2) sedation of non-intubated patients prior to and/or during surgical and other
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`procedures.
`
`8.
`
`Under 21 U.S.C. § 355(b)(1), Hospira listed the Patents-in-Suit in FDA’s
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`“Approved Drug Products with Therapeutic Equivalence Evaluations” (“the Orange Book”) as
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`covering Precedex Premix.
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`9.
`
`By letter dated June 26, 2015, and received June 30, 2015, Amneal informed
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`Hospira that it filed its ANDA with the FDA seeking approval to market its ANDA Products
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`prior to the expiry of the Patents-in-Suit. The letter notified Hospira that the ANDA contained a
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`certification under 21 U.S.C. § 355(j)(2)(a)(vii)(IV) (“Paragraph IV Certification”) that the
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`Patents-in-Suit were invalid and/or would not be infringed by Amneal.
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`10.
`
`On August 10, 2015, within 45 days of receiving Amneal’s letter, Hospira filed
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`suit against Amneal for infringement of the Patents-in-Suit by virtue of Amneal’s filing of its
`
`ANDA with a Paragraph IV Certification. (D.I. 1.) Hospira requested, among other things, an
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`Order that the effective date of any approval of the Amneal ANDA be no earlier than the
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`expiration of the Patents-in-Suit (including extensions), and an injunction enjoining Amneal
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`from engaging in the commercial manufacture, use, offer for sale, sale, and/or importation into
`
`2
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`

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`the United States of the Amneal ANDA Products until the expiration of the Patents-in-Suit
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`(including extensions). (D.I. 1 at 7-9.)
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`11.
`
`Amneal answered Hospira’s Complaint on September 1, 2015. (D.I. 9.) Amneal
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`denied that Hospira was entitled to its requested relief and counter-claimed for declaratory
`
`judgments of non-infringement and invalidity of the Patents-in-Suit.
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`12.
`
`Less than a year later, on August 10, 2016, Amneal filed petitions for inter partes
`
`review (“IPR”) of each asserted patent. The PTO instituted review of Amneal’s petitions related
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`to the ‘158, ‘470, and ‘527 patents. The PTO denied institution on the ‘106 patent. By joint
`
`request of the parties, the IPRs of the ‘158, ‘470, and ‘527 patents were terminated on May 19,
`
`2017. There are no IPRs related to the Patents-in-Suit pending at this time.
`
`13.
`
`To streamline the issues for trial, Hospira alleges that Amneal’s submission of its
`
`ANDA with Paragraph IV Certification constitutes infringement of the following claims of the
`
`Patents-in-Suit (“Asserted Claims”):
`
`•
`•
`•
`•
`
`14.
`
`‘158 patent: Claims 1-4
`‘470 patent: Claims 1-7
`‘527 patent: Claims 1 and 5
`‘106 patent: Claims 1-9.
`
`The parties disputed the meaning of certain claim terms of the Patents-in-Suit.
`
`Following briefing, the Court issued a claim construction ruling on May 25, 2016. (D.I. 57.)
`
`B.
`
`15.
`
`Jurisdiction
`
`This action arises under the patent laws of the United States, 35 U.S.C. §§ 1 et
`
`seq., including 35 U.S.C. § 271(e)(2)(A).
`
`16.
`
`This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and
`
`1338(a). No party contests subject-matter jurisdiction.
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`
`
`3
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`

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`17.
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`The Court has personal jurisdiction over the parties. No party contests personal
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`jurisdiction.
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`18.
`
`19.
`
`No party contests venue for the purposes of this litigation only.
`
`The facts supporting jurisdiction are set forth in the Statement of Undisputed
`
`Facts (Exhibit A).
`
`II.
`
`FACTS
`
`A.
`
`20.
`
`Undisputed Facts
`
`The parties stipulate to and admit the facts set forth in Exhibit A. These
`
`undisputed facts require no proof at trial and will become part of the evidentiary record in this
`
`case.
`
`B.
`
`21.
`
`22.
`
`23.
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`Disputed Facts
`
`Hospira’s statement of the disputed issues of fact is set forth in Exhibit B.
`
`Amneal’s statement of the disputed issues of fact is set forth in Exhibit C.
`
`If any statement in a party’s statement of disputed issues of fact should properly
`
`be considered as an issue of law, then that statement shall be considered as an issue of law.
`
`III.
`
`ISSUES OF LAW
`
`24.
`
`Hospira’s statement of the issues of law that remain to be litigated is set forth in
`
`Exhibit D.
`
`25.
`
`Amneal’s statement of the issues of law that remain to be litigated is set forth in
`
`Exhibit E.
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`26.
`
`If any statement in a party’s statement of the issues of law that remain to be
`
`litigated should properly be considered as an issue of fact, then that statement shall be considered
`
`as an issue of fact.
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`4
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`
`IV.
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`TRIAL EXHIBITS
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`27.
`
`Hospira’s list of pre-marked exhibits that it intends to offer at trial, including
`
`Amneal’s objections thereto (if any), is set forth in Exhibit F.
`
`28.
`
`Amneal’s list of pre-marked exhibits that it intends to offer at trial, including
`
`Hospira’s objections thereto (if any), is set forth in Exhibit G.
`
`29.
`
`Each Exhibit List contains all Exhibits that a party may present at trial other than
`
`solely for impeachment. Each Exhibit List may contain some Exhibits that may be admissible
`
`solely for impeachment or solely for other limited purposes.
`
`30.
`
`The parties’ Exhibit Lists identify the basis for the opposing party’s objection(s),
`
`if any, to each listed Exhibit. The parties will continue to negotiate regarding objections and will
`
`provide the Court with updated Exhibit Lists noting any further evidentiary stipulations at a time
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`closer to trial, as directed by the Court.
`
`31.
`
`Neither party will remove a document once it has been added to the party’s
`
`Exhibit List without agreement from the other party, unless it provides the other party the
`
`opportunity to add the document to the other party’s Exhibit List.
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`32.
`
`The parties agree that any description of a document on an Exhibit List is
`
`provided for convenience only and shall not be used as an admission or otherwise as evidence
`
`regarding the listed document or any other listed document.
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`33.
`
`The listing of an Exhibit does not constitute an admission as to the admissibility
`
`of the Exhibit (i.e., a waiver of any applicable objection). Each party reserves the right to object
`
`to the relevance or admissibility of any Exhibit offered by another party, at the time such Exhibit
`
`is offered, in view of the specific context in which such Exhibit is offered, or for any other
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`reason as set forth in the Federal Rules of Evidence or other applicable principles of law.
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`
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`5
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`34.
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`Any Exhibit identified on a party’s Exhibit List to which there is no objection is
`
`deemed to be admissible and may be entered into evidence by that party, except that nothing
`
`herein shall be construed as a stipulation or admission that the Exhibit is entitled to any weight in
`
`deciding the merits of the case.
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`35.
`
`Statements by a party opponent from any request for admission responses,
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`interrogatory responses, document requests, or pleadings may be read at trial and need not be
`
`included on an Exhibit List.
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`36.
`
`The parties agree to disclose supplemental Exhibits promptly after identification.
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`Reasonable supplementation of Exhibit Lists will be permitted until August 14, 2017, at 6pm
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`Eastern, after which time no supplemental Exhibits may be provided. Objections to
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`supplemental Exhibits must be served no later than August 15, 2017, at 6pm Eastern.
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`37.
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`Authenticity of Exhibits: Any document produced from a party’s files, and that is
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`a document prepared by the party (as well as FDA correspondence relating to the Precedex NDA
`
`and the Amneal ANDA) shall be deemed prima facie authentic, subject to the right of any party
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`against whom such document is offered to adduce evidence to the contrary or to require that the
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`offering party provide authenticating evidence if the opposing party has a reasonable basis to
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`believe that the document is not authentic.
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`38.
`
`Admissibility of Exhibits: The following are admissible in whole or in part: (1)
`
`the Patents-in-Suit; (2) the prosecution histories of the Patents-in-Suit; (3) the Amneal ANDA.
`
`39.
`
`Each party reserves the right to offer an Exhibit included on the opposing party’s
`
`final Exhibit List, even if the opposing party does not offer the Exhibit into evidence. The
`
`opposing party shall be entitled to pose any objections that it may have as to admissibility.
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`6
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`40.
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`Demonstrative Exhibits need not be listed on the parties’ Exhibit Lists. The party
`
`seeking to use a Demonstrative Exhibit will provide a color representation of the Demonstrative
`
`Exhibit to the opposing party in .pdf, .ppt, or another commonly viewable format, pursuant to the
`
`schedule below.
`
`41.
`
`Each party will exchange by e-mail any Demonstrative Exhibit by 7pm Eastern
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`two calendar days before the Exhibit will first be used at trial. For example, a Demonstrative
`
`Exhibit intended for use at trial on Monday, August 21, 2017, would be exchanged no later than
`
`7pm Eastern on Saturday, August 19, 2017. The party receiving identification of a
`
`Demonstrative Exhibit shall inform the party identifying the Exhibit of any objection by 9pm
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`Eastern on the day of receipt of identification of the Exhibit. The parties shall meet-and-confer
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`as soon as reasonably possible thereafter to resolve any such objections. The provision applies to
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`Demonstrative Exhibits used in opening statements and Demonstrative Exhibits intended for use
`
`in direct examination of non-adverse witnesses.
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`42.
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`For Demonstrative Exhibits used in closing arguments (if permitted) that have not
`
`previously been disclosed, the parties will exchange by e-mail any Demonstrative Exhibit by
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`8pm Eastern on the day before it will be used at trial (or as soon after 8pm as the trial schedule
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`for that day allows). The party receiving identification of a Demonstrative Exhibit shall inform
`
`the party identifying the Exhibit of any objections by 9pm Eastern on the day of receipt, and the
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`parties shall meet-and-confer as soon as reasonably possible thereafter to resolve any such
`
`objections.
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`43.
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`If any Demonstrative Exhibit changes after the deadline for disclosure, the party
`
`intending to use the Exhibit shall promptly notify the opposing party of the changes, and the
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`opposing party may pose appropriate objections within a reasonable time.
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`7
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`44.
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`For each Demonstrative Exhibit that is based on a document or documents
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`produced in discovery, the party offering the Demonstrative Exhibit shall disclose to the
`
`opposing party, either (1) on the face of the Exhibit or (b) in a table or other writing provided at
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`the time the exhibit is exchanged, all documents that form the basis of the exhibit. The
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`documents shall be identified by Trial Exhibit number.
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`45.
`
`Each party shall also provide by e-mail to opposing counsel a listing of all
`
`Exhibits a party intends to use during direct examination of a non-adverse witness by 7pm
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`Eastern two calendar days before they will be used at trial. For example, a listing of all Exhibits
`
`intended for use during direct examination of non-adverse witnesses on Monday, August 21,
`
`2017, would be exchanged by e-mail no later than 7pm Eastern on Saturday, August 19, 2017.
`
`46.
`
`The party receiving identification of Exhibits intended for use in direct
`
`examination of non-adverse witnesses shall inform the party identifying the Exhibits of any
`
`objections by 9pm Eastern on the day of receipt of the Exhibits. The parties shall meet and
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`confer as soon as reasonably possible thereafter to resolve such objections.
`
`47.
`
`The advance notification procedures for Exhibits described above do not apply to
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`Demonstrative Exhibits created in the courtroom during live testimony, Demonstrative Exhibits
`
`intended for use in cross-examination, or to excerpts, enlargements, and/or highlights of the text
`
`of Exhibits that already appear on a party’s Exhibit List or previously have been properly
`
`identified for use during the examination of a witness.
`
`48.
`
`If good-faith efforts to resolve objections to an Exhibit fail, the objecting party
`
`shall bring its objections to the Court’s attention before the opening statements or before the
`
`applicable witness is called to the witness stand.
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`8
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`
`V. WITNESS LISTS
`
`49.
`
`Hospira’s list of potential fact and expert witnesses that it may call to testify, and
`
`Amneal’s objections thereto (if any), is set forth in Exhibit H.
`
`50.
`
`Amneal’s list of potential fact and expert witnesses that it may call to testify, and
`
`Hospira’s objections thereto (if any), is set forth in Exhibit I.
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`51. Witnesses whose testimony is expected to be by means of a deposition are so
`
`designated on the parties’ Witness Lists.
`
`52.
`
`The parties expect to present some or all of the witnesses identified in their
`
`respective witness lists either live or by deposition (written transcript and/or video) as indicated.
`
`53.
`
`The parties’ Witness Lists represent the parties’ good-faith understanding and
`
`expectation about which witnesses are expected to be called live at trial. To the extent that a
`
`witness’ circumstances change, or a witness otherwise becomes unavailable for trial, each party
`
`reserves the right to call that witness by deposition, subject to resolution of objections by the
`
`opposing party.
`
`54.
`
`The parties further reserve the right to call: (1) one or more additional witnesses
`
`whose testimony is necessary to establish authenticity or admissibility of any Exhibit in response
`
`to a challenge as to the authenticity or admissibility of the Exhibit; and (2) additional witnesses
`
`to respond to any issues raised by the Court’s pretrial or trial rulings.
`
`55.
`
`Except as set forth herein, no fact or expert witness called by a party shall be
`
`permitted to testify at trial unless identified on a party’s witness list.
`
`56.
`
`By 7pm Eastern two calendar days before a witness will be called to testify
`
`(whether live or by deposition), the name of the witness will be identified by e-mail to opposing
`
`counsel, along with an explanation of whether the witness will testify live or by deposition, as
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`9
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`well as the expected order of presentation. Thereafter, each party shall update its list of expected
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`witnesses at the end of each trial day.
`
`57.
`
`For witnesses testifying by deposition, the introducing party shall identify the
`
`particular designated deposition testimony (by page and line numbers) that are actually intended
`
`to be played or read at trial, or a disclosure that all pages and lines previously designated will be
`
`played, by 7pm Eastern two calendar days before introducing the deposition testimony. By 9am
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`Eastern on the next calendar day, the opposing party shall identify any specific pages and lines
`
`from that deposition testimony to counter-designate and any testimony to which it maintains an
`
`objection. The parties shall meet and confer to resolve any objections. To provide the
`
`introducing party adequate time to prepare any necessary video/DVD of the testimony, a final
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`meet-and-confer shall be conducted, if necessary, by 6pm Eastern on the calendar day before the
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`testimony is to be introduced. If the parties are unable to resolve objections to disputed
`
`testimony, they shall present such objections to the Court on the day of intended deposition use
`
`at an appropriate time before the testimony is to be presented.
`
`58.
`
`Each party shall give notice by e-mail to the opposing party by 7pm Eastern two
`
`calendar days before it expects to complete its presentation of evidence. By 9am Eastern the
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`following calendar day, the opposing party shall identify by e-mail the witness(es) that it intends
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`to call on the first day of its case-in-chief rebuttal.
`
`VI.
`
`DEPOSITION DESIGNATIONS
`
`59.
`
`Hospira’s designations of deposition testimony that it may use at trial, Amneal’s
`
`counter-designations, and objections thereto are set forth in Exhibit J. Hospira reserves the right
`
`to designate any testimony that Amneal has counter-designated but which Amneal withdraws
`
`before or during trial. Amneal shall be entitled to raise any objections to admissibility of any
`
`such withdrawn / re-designated testimony.
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`10
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`60.
`
`Amneal’s designations of deposition testimony that it may use at trial, Hospira’s
`
`counter-designations, and objections thereto are set forth in Exhibit K. Amneal reserves the right
`
`to designate any testimony that Hospira has counter-designated but which Hospira withdraws
`
`before or during trial. Hospira shall be entitled to raise any objections to admissibility of any
`
`such withdrawn / re-designated testimony.
`
`61.
`
`The parties may not list new deposition designations or counter-designations, or
`
`provide new objections to listed designations or counter-designations, except for good cause
`
`shown or by agreement of the parties.
`
`62.
`
`If a party withdraws any of its deposition designations before or during trial, the
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`opposing party may still use (a) any of its counter-designations irrespective of the withdrawn
`
`designations, subject to any previously-asserted objections as to admissibility, and (b) any of the
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`withdrawn designations as counter-designations, subject to any objections as to admissibility of
`
`any such withdrawn / re-designated testimony.
`
`63.
`
`Any deposition testimony not specifically identified on a party’s deposition
`
`designation list may still be used at trial for the purpose of impeachment, if otherwise competent
`
`for such purpose.
`
`64.
`
`If applicable, a party’s designation of a page and line from a particular transcript
`
`shall be automatically deemed to include any errata indicated for that page and line in the
`
`associated errata sheets.
`
`65. When deposition designations are introduced, all counter-designations will also be
`
`introduced in the sequence in which the testimony was originally given. All colloquy between
`
`counsel and objections shall be eliminated when the deposition is read or played at trial. To the
`
`extent that deposition designations are read or played at trial, each party will be charged for the
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`11
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`time taken to read or play its designations, as measured by the proportion of lines of testimony
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`for its designations to the total number of lines of testimony read or played.
`
`66.
`
`If a party chooses to read a witness’ designations at trial, all counter-designations
`
`will also be read. If a party chooses to play video of a witness’ designations at trial, all counter-
`
`designations will also be played in video.
`
`VII.
`
`ITEMIZED LIST OF SPECIAL DAMAGES
`
`67.
`
`68.
`
`This case does not involve a damages claim.
`
`Each party reserves its respective right to seek its attorneys’ fees and costs
`
`pursuant to 35 U.S.C. § 285.
`
`VIII. STATEMENTS OF INTENDED PROOFS
`
`69.
`
`A brief statement of what Hospira intends to prove in support of its claims is set
`
`forth in Exhibit L.
`
`70.
`
`A brief statement of what Amneal intends to prove in support of its defenses and
`
`counterclaims is set forth in Exhibit M.
`
`IX.
`
`DESIRED AMENDMENTS TO THE PLEADINGS
`
`71.
`
`The parties do not seek any amendments to the pleadings.
`
`X.
`
`CERTIFICATION OF ATTEMPTED RESOLUTION OF CONTROVERSY
`
`72.
`
`The parties engaged in good-faith efforts to explore the resolution of this case by
`
`settlement. To date, no agreement has been reached.
`
`XI. MOTIONS IN LIMINE
`
`73.
`
`None.
`
`XII. TRIAL PARAMETERS
`
`74.
`
`This is a non-jury trial, as there are no triable issues to a jury as a matter of right.
`
`12
`
`

`

`Case 1:15-cv-00697-RGA Document 99 Filed 08/14/17 Page 16 of 17 PageID #: 1277
`
`
`75.
`
`The parties propose a trial time of 20 hours, with each party allotted half of the
`
`time.
`
`76.
`
`Order of proof: First, Hospira shall present its affirmative case on infringement.
`
`Second, Amneal shall present its rebuttal case on infringement and its affirmative case on
`
`invalidity. Third, Hospira shall present its reply case on infringement and its rebuttal case on
`
`invalidity (including objective indicia of non-obviousness). Fourth, Amneal shall present its
`
`reply case on invalidity.
`
`
`
`
`
`
`
`CONNOLLY GALLAGHER LLP
`
`
`
`/s/ Ryan P. Newell
`Arthur G. Connolly, III (#2667)
`Ryan P. Newell (#4744)
`The Brandywine Building
`1000 West Street
`Wilmington, DE 19801
`(302) 757-7300
`aconnolly@connollygallagher.com
`rnewell@connollygallagher.com
`
`Attorneys for Plaintiff Hospira, Inc.
`
`OF COUNSEL:
`
`Bradford P. Lyerla
`Sara T. Horton
`Yusuf Esat
`Chad J. Ray
`JENNER & BLOCK LLP
`353 N. Clark Street Chicago, IL 60654-3456
`Telephone: 312 222-9350
`Facsimile: 312 527-0484
`blyerla@jenner.com
`shorton@jenner.com
`yesat@jenner.com
`cray@jenner.com
`
`
`
`
`
`
`RICHARDS, LAYTON & FINGER, P.A.
`
`
`
`/s/ Kelly E. Farnan
`Frederick L. Cottrell III (#2555)
`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@rlf.com
`
`Attorneys for Defendant-Counterclaim Plaintiff
`Amneal Pharmaceuticals LLC
`
`OF COUNSEL:
`
`Steven A. Maddox
`Jeremy J. Edwards
`Matthew C. Ruedy
`MADDOX EDWARDS PLLC
`1900 K ST NW Suite 725
`Washington, D.C. 2006
`smaddox@meiplaw.com
`JEdwards@meiplaw.com
`MRuedy@meiplaw.com
`
`
`
`Michael R. Dzwonczyk
`
`
`
`13
`
`

`

`Case 1:15-cv-00697-RGA Document 99 Filed 08/14/17 Page 17 of 17 PageID #: 1278
`
`Azy S. Kokabi
`Grant S. Shackelford
`SUGHRUE MION, PLLC
`2100 Pennsylvania Ave., NW
`Washington, DC 20037
`(202) 293-7060
`mdzwonczyk@sughrue.com
`akokabi@sughrue.com
`gshackelford@sughrue.com
`
`Dated: August 7, 2017
`
`PUBLIC VERSION: Filed August 14, 2017
`
`14
`
`