`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MASSACHUSETTS
`
`
`
`TEVA PHARMACEUTICALS
`
`INTERNATIONAL GMBH
`
`and TEVA
`
`PHARMACEUTICALS USA,
`
`INC.,
`
`Plaintiffs,
`
`v.
`
`ELI LILLY AND COMPANY,
`
`
`
`
`
`
`Defendant.
`
`
`
`
`
`
`
`
`
`Civil Action No.
`1:18-cv-12029-ADB
`
`UNOPPOSED MOTION TO EXTEND TIME TO DECEMBER 4, 2018 TO RESPOND
`TO DEFENDANT’S COUNTERCLAIMS AND MOTION TO TRANSFER/STAY
`
`Plaintiffs Teva Pharmaceuticals International GmbH and Teva Pharmaceuticals USA,
`
`Inc. (collectively, “Plaintiffs”) hereby move this Court to extend—up to and including December
`
`4, 2018—the time for Plaintiffs to file (1) their response to Defendant’s Counterclaims (D. 17,
`
`filed on November 2, 2018) and (2) their response to Defendant’s Motion to Transfer, Or If Not
`
`Transferred, Then To Stay This Litigation Pending Inter Partes Review (“Defendant’s Motion”)
`
`(D. 18, filed on November 2, 2018). These extensions will allow sufficient time for Plaintiffs
`
`and their counsel to complete the required investigation and review of the allegations to prepare
`
`their responses to Defendant’s Counterclaims and Defendant’s Motion. These extensions will
`
`not cause a material delay in this action. Defendant does not oppose this motion.
`
`WHEREFORE, the Parties respectfully request allowance of this motion.
`
`
`
`
`
`Case 1:18-cv-12029-ADB Document 21 Filed 11/13/18 Page 2 of 3
`
`Dated: November 13, 2018
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Douglas J. Kline
`Douglas J. Kline (BBO# 556680)
`Elaine Herrmann Blais (BBO# 656142)
`Robert Frederickson, III (BBO# 670111)
`Alexandra Lu (BBO# 676756)
`Eric T. Romeo (BBO# 691591)
`Martin C. Topol (BBO# 696020)
`GOODWIN PROCTER LLP
`100 Northern Avenue
`Boston, MA 02210
`Tel.: (617) 570-1000
`Fax: (617) 523-1231
`dkline@goodwinlaw.com
`eblais@goodwinlaw.com
`rfrederickson@goodwinlaw.com
`alu@goodwinlaw.com
`eromeo@goodwinlaw.com
`mtopol@goodwinlaw.com
`
`Neel Chatterjee (pro hac vice forthcoming)
`GOODWIN PROCTER LLP
`135 Commonwealth Drive
`Menlo Park, CA 94025
`Tel.: (650) 752-3100
`Fax: (650) 853-1038
`nchatterjee@goodwinlaw.com
`
`Natasha E. Daughtrey
`(pro hac vice forthcoming)
`GOODWIN PROCTER LLP
`601 S. Figueroa Street
`Los Angeles, CA 90017
`Tel.: (213) 426-2500
`Fax: (213) 623-1673
`ndaughtrey@goodwinlaw.com
`
`Attorneys for Plaintiffs
`
`
`
`2
`
`
`
`Case 1:18-cv-12029-ADB Document 21 Filed 11/13/18 Page 3 of 3
`
`LOCAL RULE 7.1(a)(2) CERTIFICATE
`
`
`The undersigned certifies pursuant to Local rule 7.1(a)(2), that the moving party has
`
`conferred in good faith with opposing counsel on the matters set forth in the foregoing motion in
`an attempt to resolve or narrow the issues and reports that opposing counsel does not oppose the
`relief sought herein.
`
`
`
`
`
`
`
`
`
`/s/ Douglas J. Kline
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I, Douglas J. Kline, hereby certify that a copy of the foregoing document, filed through
`the CM/ECF system, will be sent electronically to the registered participants as identified on the
`Notice of Electronic Filing (NEF) and paper copies shall be served by first class mail postage
`prepaid on all counsel of record who are not served through the CM/ECF system on November
`13, 2018.
`
`/s/ Douglas J. Kline
`
`
`
`
`
`3
`
`
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