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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 17-1672-GMS
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`GENENTECH, INC. and CITY OF HOPE,
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`Plaintiffs and Counterclaim Defendants,
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`v.
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`PFIZER INC.,
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`Defendant and Counterclaim Plaintiff.
`__________________________________________)
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`SUPPLEMENTAL JOINT STATUS REPORT
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`The parties hereby submit this supplemental joint status report to update the Court on two
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`issues addressed in the Joint Status Report submitted on February 12, 2018 (D.I. 15).
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`Discovery Limits
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`In the Joint Status Report (D.I. 15 at 10), the parties stated that they would confer
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`regarding appropriate discovery limits for this action upon the completion of the parties’
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`exchanges under the BPCIA in March 2018 and agreed to submit a joint proposal for discovery
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`limits by March 16, 2018. Having now completed the BPCIA exchanges, the parties have
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`discussed case narrowing and jointly propose the following limits on discovery:
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`Requests for Production: No limit.
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`Interrogatories: Up to 50 interrogatories by each side to any other side.
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`Requests for Admission: Up to 150 requests for admission by each side to any other side,
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`exclusive of requests for admission to authenticate documents. The parties will work together to
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`reach an agreement concerning the authenticity of the parties’ respective documents to reduce
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`the need for requests for admission to authenticate documents.
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`RLF1 19025450v.1
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`Case 1:17-cv-01672-GMS Document 16 Filed 03/16/18 Page 2 of 4 PageID #: 1849
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`Fact Depositions: Up to 250 hours of depositions for each side for any fact witnesses,
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`including Rule 30(b)(6) depositions and depositions of third parties. All depositions of current
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`employees of the parties, inventors, and Rule 30(b)(6) witnesses of the parties will occur in the
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`United States.
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`These discovery limits are based upon the parties’ current understanding of the scope of
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`the case. The parties agree to confer in good faith regarding these discovery limits should the
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`scope of the case change in the future.
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`Amended Complaint
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`In the Joint Status Report (D.I. 15 at 10), the parties proposed a March 16, 2018 deadline
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`by which Genentech was to file an amended complaint reflecting any case narrowing upon the
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`completion of exchanges under the BPCIA. The parties are currently discussing Genentech’s
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`proposed amended complaint and a potential stipulation to dismiss certain patents from the case.
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`The parties jointly agree to extend the proposed deadline for Genentech to file an amended
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`complaint to March 23, 2018.
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`RLF1 19025450v.1
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`2
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`Case 1:17-cv-01672-GMS Document 16 Filed 03/16/18 Page 3 of 4 PageID #: 1850
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`/s/ Dominick T. Gattuso
`Dominick T. Gattuso (#3630)
`HEYMAN ENERIO GATTUSO & HIRZEL LLP
`300 Delaware Avenue, Suite 200
`Wilmington, DE 19801
`(302) 472-7300
`dgattuso@hegh.law
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`OF COUNSEL:
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`Thomas J. Meloro
`Michael W. Johnson
`Diana G. Santos
`Dan Constantinescu
`WILLKIE FARR & GALLAGHER LLP
`787 Seventh Avenue
`New York, NY
`tmeloro@willkie.com
`mjohnson1@willkie.com
`dsantos@willkie.com
`dconstantinescu@willkie.com
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`Attorneys for Defendant Pfizer, Inc.
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`/s/ Jason J. Rawnsley
`Frederick L. Cottrell, III (#2555)
`Jason J. Rawnsley (#5379)
`RICHARDS, LAYTON & FINGER, P.A.
`One Rodney Square
`920 North King Street
`Wilmington, DE 19801
`(302) 651-7700
`cottrell@rlf.com
`rawnsley@rlf.com
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`OF COUNSEL:
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`William F. Lee
`Lisa J. Pirozzolo
`Emily R. Whelan
`Kevin S. Prussia
`Andrew J. Danford
`WILMER CUTLER PICKERING
`HALE AND DORR LLP
`60 State Street
`Boston, MA 02109
`(627) 526-6000
`william.lee@wilmerhale.com
`lisa.pirozzolo@wilmerhale.com
`emily.whelan@wilmerhale.com
`kevin.prussia@wilmerhale.com
`andrew.danford@wilmerhale.com
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`Robert J. Gunther Jr.
`WILMER CUTLER PICKERING
`HALE AND DORR LLP
`7 World Trade Center
`250 Greenwich Street
`New York, NY 10007
`(212) 230-8800
`robert.gunther@wilmerhale.com
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`Robert M. Galvin
`WILMER CUTLER PICKERING
`HALE AND DORR LLP
`950 Page Mill Road
`Palo Alto, CA 94304
`(650) 858-6000
`robert.galvin@wilmerhale.com
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`RLF1 19025450v.1
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`Case 1:17-cv-01672-GMS Document 16 Filed 03/16/18 Page 4 of 4 PageID #: 1851
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`Daralyn J. Durie
`Adam R. Brausa
`DURIE TANGRI LLP
`217 Leidesdorff St.
`San Francisco, CA 94111
`(415) 362-6666
`ddurie@durietangri.com
`abrausa@durietangri.com
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`Attorneys for Plaintiffs Genentech, Inc.
`and City of Hope
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`Dated: March 16, 2018
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`RLF1 19025450v.1
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`4
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