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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`)))))))))
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`BAXTER HEALTHCARE CORPORATION,
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`Plaintiff,
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`v.
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`HOSPIRA, INC. and ORION CORP.,
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`Defendants.
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`C.A. No. 18-303-RGA
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`HOSPIRA, INC.’S MOTION FOR A FOURTEEN (14) DAY EXTENSION
`OF TIME TO ANSWER, MOVE OR OTHERWISE RESPOND TO COMPLAINT
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`Pursuant to Fed. R. Civ. P. 6(b)(1), Defendant Hospira, Inc. (“Hospira”) respectfully
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`moves for a fourteen (14) day extension of time to answer, move or otherwise respond to the
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`Complaint (D.I. 1) (the “Motion”). Pursuant to District of Delaware Local Rule 7.1.1, counsel
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`for Hospira has conferred with counsel for Plaintiff Baxter Healthcare Corporation (“Baxter”).
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`Baxter opposes the Motion.
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`Hospira respectfully represents as follows in support of the Motion:
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`1.
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`2.
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`On February 22, 2018, Baxter filed the Complaint (D.I. 1) in this action.
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`Hospira was served with the Complaint on February 23, 2018 (D.I. 5). Hospira’s
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`response to the Complaint is due on March 16, 2018.
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`3.
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`Hospira seeks a modest extension of time to respond to the Complaint in order to
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`investigate the allegations of the Complaint, to consider how it will respond to the Complaint and
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`to consult with its attorneys regarding a proposed course of action. This is the first extension of
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`time to respond to the Complaint requested by Hospira.
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`{05377425.DOCX.}
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`Case 1:18-cv-00303-RGA Document 7 Filed 03/16/18 Page 2 of 2 PageID #: 102
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`4.
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`This Court has discretion to grant a motion to extend the time to file a responsive
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`pleading for good cause. Fed. R. Civ. P. 6(b)(1). Hospira respectfully submits that for the
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`reasons set for the above, it has established good cause for a short, fourteen (14) day extension of
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`time to respond to the Complaint.
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`5.
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`As a result of this Court’s holiday on March 30, 2018, Hospira’s response to the
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`Complaint would be due on April 2, 2018 if the Motion is granted.
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`WHEREFORE, Hospira respectfully requests the entry of an order extending the time by
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`fourteen (14) days for it to answer, move or otherwise respond to the Complaint permitting it to
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`respond to the file the Reply Brief within one day of such order.
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`Dated: March 16, 2018
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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
`Wilmington, DE 19801
`302) 757-7300
`aconnolly@connollygallagher.com
`rnewell@connollygallagher.com
`Attorneys for Defendant Hospira, Inc.
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`SO ORDERED this _____ day of _____________, 2018.
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`____________________________________
`United States District Judge
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`{05377425.DOCX.}
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`2
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