`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 18-303-RGA
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`
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`Plaintiff,
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`Defendants.
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`v.
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`BAXTER HEALTHCARE
`CORPORATION,
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`
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`HOSPIRA, INC. and ORION CORP.,
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`
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`STIPULATION AND [PROPOSED] ORDER
`REGARDING EXTENSION OF FACT DISCOVERY
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`
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`WHEREAS, fact discovery closes November 15, 2018 (D.I. 21);
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`WHEREAS Plaintiff Baxter Healthcare Corporation (“Plaintiff”) and Defendants
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`Hospira, Inc. and Orion Corp. (collectively, “Defendants”) are discussing extending that deadline
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`and other dates in the schedule, but have not agreed on all dates;
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`WHEREAS under either party’s proposal, fact discovery would continue to at least
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`April 1, 2019;
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`WHEREAS the parties request, subject to the Court’s approval, that the fact discovery
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`deadline be provisionally extended until April 1, 2019 and after the parties complete their
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`discussions on the rest of the new schedule, the parties will inform the Court of the requested
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`new schedule or whether they have disputes;
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`
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`NOW THEREFORE, IT IS HEREBY STIPULATED by Plaintiff and Defendants,
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`subject to the approval of the Court, that the deadline to complete fact discovery is extended to
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`April 1, 2019.
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`Dated: November 14, 2018
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`POTTER ANDERSON & CORROON LLP
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`By: /s/ Philip A. Rovner
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`Philip A. Rovner (#3215)
`Jonathan A. Choa (#5319)
`Alan R. Silverstein (#5066)
`Hercules Plaza
`P.O. Box 951
`Wilmington, DE 19899
`(302) 984-6000
`provner@potteranderson.com
`jchoa@potteranderson.com
`asilverstein@potteranderson.com
`
`
` Attorneys for Plaintiff
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`CONNOLLY GALLAGHER LLP
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`
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`/s/ Arthur G. Connolly, III
`Arthur G. Connolly, III (#2667)
`Ryan P. Newell (#4744)
`The Brandywine Building
`1000 West Street, Suite 1400
`Wilmington, DE 19801
`(302) 757-7300
`aconnolly@connollygallagher.com
`rnewell@connollygallagher.com
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`Attorneys for Defendants
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`SO ORDERED this ____ day of November, 2018
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`______________________________________
`THE HONORABLE RICHARD G. ANDREWS
`UNITED STATES DISTRICT JUDGE
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`
`
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