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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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`STIPULATION AND PROPOSED ORDER REGARDING AMENDED COMPLAINT
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`WHEREAS, on November 17, 2017, Plaintiffs Genentech, Inc. and City of Hope
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`(collectively, “Plaintiffs”) filed the above-captioned action against Defendant Pfizer Inc.
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`(“Pfizer”);
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`WHEREAS, in the Joint Status Report, D.I. 15 at p. 10, and Supplemental Joint Status
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`Report, D.I. 16 at p. 2, the parties jointly proposed a deadline for Plaintiffs to file an Amended
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`Complaint reflecting case narrowing; and
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`WHEREAS, Plaintiffs seek leave to amend the complaint (D.I. 1) in this action to reflect
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`such case narrowing, and Pfizer does not oppose such amendment;
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` NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between
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`the undersigned parties and subject to the Court’s approval, that pursuant to Fed. R. Civ. P. 15(a)
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`and D. Del. L.R. 15.1, and in the interests of judicial efficiency, the proposed amended pleading
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`attached hereto as Exhibit A shall be docketed by the Court as the amended pleading and shall be
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`deemed served upon filing. A form of the amended pleading indicating in what respect it differs
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`from the pleading which it amends is attached as Exhibit B.
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`RLF1 19047104v.1
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`Case 1:17-cv-01672-GMS Document 19 Filed 03/23/18 Page 2 of 2 PageID #: 1857
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`/s/ Jason J. Rawnsley
`Frederick L. Cottrell, III (#2555)
`Jason J. Rawnsley (#5379)
`RICHARDS LAYTON & FINGER, P.A.
`920 North King Street
`Wilmington, DE 19801
`(302) 651-7700
`cottrell@rlf.com
`rawnsley@rlf.com
`Counsel for Plaintiffs Genentech, Inc. and
` City of Hope
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`Dated: March 23, 2018
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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
`Counsel for Defendant Pfizer Inc.
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`SO ORDERED this _____ day of ______________, 2018.
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`The Honorable Gregory M. Sleet
`Senior Judge
`United States District Court
`District of Delaware
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`RLF1 19047104v.1
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`2
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