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`BY CM/ECF & HAND DELIVERY
`The Honorable Leonard P. Stark
`United States District Court
`844 N. King Street
`Wilmington, DE 19801
`
`
`
`
`
`
`Re:
`
`
`Dear Chief Judge Stark:
`
`
`Case 1:16-cv-01221-LPS Document 73 Filed 07/30/18 Page 1 of 2 PageID #: 678
`
` 
`
`July 30, 2018
`
`Nathan R. Hoeschen 
`I.M. Pei Building 
`1105 North Market Street, 12th Floor 
`Wilmington, DE 19801 
`(302) 298‐0700 
`(302) 298‐0709 ‐ Direct 
`nhoeschen@shawkeller.com 
`
`Bayer Healthcare LLC, et al. v. Teva Pharmaceuticals USA, Inc.,
`C.A. No. 16-1221-LPS
`
`The parties in the above referenced matter write to request the scheduling of a discovery
`teleconference.
`
`
`The following attorneys, including at least one Delaware Counsel and at least one Lead
`Counsel per party, participated in a verbal meet-and-confer (in person and/or by telephone) on
`the following date(s), one or more of which relate to the disputes identified below:
`
`March 2, 2018
`
`Delaware Counsel: Derek Fahnestock (Plaintiffs)
`
`
`
`David Frye (Teva Defendant)
`
`
`
`Kenneth Dorsney (Apotex Defendant)
`
`
`
`
`Lead Counsel:
`Jessica Rydstrom, Seth Bowers, Ben Picozzi (Plaintiffs)
`
`
`
`Jennell Bilek, Shelleaha Jonas (Teva Defendant)
`
`
`
`Philip Kouyoumdjian (Apotex Defendant)
`
`April 19, 2018
`
`Delaware Counsel: Derek Fahnestock (Plaintiffs)
`
`
`
`David Frye (Teva Defendant)
`
`
`
`Charles Toliver (Apotex Defendant)
`
`
`
`
`Lead Counsel:
`Jessica Rydstrom, Dov Grossman, Ben Picozzi (Plaintiffs)
`
`
`
`Jennell Bilek, Shelleaha Jonas (Teva Defendant)
`
`
`
`Philip Kouyoumdjian (Apotex Defendant)
`
`April 30, 2018
`
`Delaware Counsel: Derek Fahnestock (Plaintiffs)
`
`
`
`

`

`Case 1:16-cv-01221-LPS Document 73 Filed 07/30/18 Page 2 of 2 PageID #: 679
`
`
`
`David Frye (Teva Defendant)
`Kenneth Dorsney (Apotex Defendant)
`
`Jessica Rydstrom, Ben Picozzi (Plaintiffs)
`Jennell Bilek, Shelleaha Jonas (Teva Defendant)
`Philip Kouyoumdjian, Ian Scott (Apotex Defendant)
`
`
`
`
`
`
`
`
`
`
`Lead Counsel:
`
`
`
`
`
`
`
`May 16, 2018
`
`Delaware Counsel: Derek Fahnestock (Plaintiffs)
`
`
`
`Nathan Hoeschen (Teva Defendant)
`
`
`
`Kenneth Dorsney (Apotex Defendant)
`
`
`
`
`Lead Counsel:
`Jessica Rydstrom, Seth Bowers (Plaintiffs)
`
`
`
`Jennell Bilek, Shelleaha Jonas (Teva Defendant)
`
`
`
`Philip Kouyoumdjian, Ian Scott (Apotex Defendant)
`
`July 13, 2018
`
`Delaware Counsel: Derek Fahnestock (Plaintiffs)
`
`
`
`Nathan Hoeschen (Teva Defendant)
`
`
`
`Kenneth Dorsney (Apotex Defendant)
`
`
`
`
`Lead Counsel:
`Ben Picozzi, Seth Bowers (Plaintiffs)
`
`
`
`Shelleaha Jonas (Teva Defendant)
`
`
`
`Philip Kouyoumdjian (Apotex Defendant)
`
`The disputes requiring judicial attention are listed below:
`
`
` Plaintiffs’ production of custodial research and development documents in
`response to Defendants’ Request Nos. 18-19, 22, and 26
` Plaintiffs’ production of certain documents from previous litigations involving
`one of the patents asserted in this case and/or the development of the invention
`claimed therein in response to Defendants’ Request Nos. 84-86 and 88-89
`
`Respectfully submitted,
`
`/s/ Nathan R. Hoeschen
`
`Nathan R. Hoeschen (No. 6232)
`
`
`
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`
`Clerk of the Court (by hand delivery)
`Counsel of Record (by CM/ECF)
`
`
`cc:
`
`
`
`2
`
`

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