`
`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. 18-12029-ADB
`
`PLAINTIFFS’ ASSENTED-TO MOTION FOR
`PRO HAC VICE ADMISSION OF I. NEEL CHATTERJEE AND NATASHA E.
`DAUGHTREY
`
`Pursuant to Local Rule 83.5.3(b), Teva Pharmaceuticals International GmbH and Teva
`
`Pharmaceuticals USA, Inc. (collectively “Teva”) by and through its undersigned counsel, hereby
`
`move for the admission pro hac vice of its counsel I. Neel Chatterjee and Natasha E. Daughtrey.
`
`As grounds, Teva states that:
`
`1.
`
`I. Neel Chatterjee is a partner at the law firm of Goodwin Procter LLP, 601
`
`Marshall Street, Redwood City, CA 94063. Attorney Chatterjee is a member in good standing of
`
`the Bar of the State of California. He has also been admitted to practice in the United States
`
`District Courts for the Northern, Central, and Southern Districts of California, the Eastern
`
`District of Texas, the District of Colorado, and the United States Courts of Appeals for the First,
`
`Ninth, and Federal Circuits.
`
`2.
`
`In further support of its motion, Teva submits as Exhibit A the Certificate of I.
`
`Neel Chatterjee which establishes that he is a member in good standing of the Bar in every
`
`jurisdiction in which he has been admitted to practice; that there are no disciplinary proceedings
`
`
`
`Case 1:18-cv-12029-ADB Document 23 Filed 11/20/18 Page 2 of 4
`
`against him in any jurisdiction; that he has not previously had a pro hac vice admission to
`
`this Court or any other court revoked for misconduct; and that he is familiar with the Local
`
`Rules of this Court.
`
`3.
`
`Natasha E. Daughtrey is a partner at the law firm of Goodwin Procter LLP, 601 S.
`
`Figueroa Street, 41st Floor, Los Angeles, CA 90017-5704. Attorney Daughtrey is a member in
`
`good standing of the Bar of the States of California and New York. She has also been admitted to
`
`practice in the United States District Courts for the Northern and Central Districts of California,
`
`the Eastern and Southern Districts of New York, and the United States Court of Appeals for the
`
`Federal Circuit.
`
`4.
`
`In further support of its motion, Teva submits as Exhibit B the Certificate of
`
`Natasha E. Daughtrey which establishes that she is a member in good standing of the Bar in
`
`every jurisdiction in which she has been admitted to practice; that there are no disciplinary
`
`proceedings against her in any jurisdiction; that she has not previously had a pro hac
`
`vice admission to this Court or any other court revoked for misconduct; and that she is
`
`familiar with the Local Rules of this Court.
`
`5.
`
`Defendant does not object to the filing of this Motion.
`
`WHEREFORE, this Court should grant the admission of attorneys I. Neel Chatterjee and
`
`Natasha E. Daughtrey pro hac vice to the Bar of this Court.
`
`2
`
`
`
`Case 1:18-cv-12029-ADB Document 23 Filed 11/20/18 Page 3 of 4
`
`Dated: November 20, 2018
`
`Respectfully submitted,
`
`/s/ Robert Frederickson III
`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
`
`I. Neel Chatterjee (pro hac vice pending)
`GOODWIN PROCTER LLP
`601 Marshall Street
`Redwood City, CA 94063
`Tel.: (650) 752-3100
`Fax: (650) 853-1038
`nchatterjee@goodwinlaw.com
`
`Natasha E. Daughtrey (pro hac vice pending)
`GOODWIN PROCTER LLP
`601 S. Figueroa Street, 41st Floor
`Los Angeles, CA 90017-5704
`Tel: 213-426-2500
`Fax: 213-623-1673
`NDaughtrey@goodwinlaw.com
`
`Attorneys for Plaintiffs
`
`3
`
`
`
`Case 1:18-cv-12029-ADB Document 23 Filed 11/20/18 Page 4 of 4
`
`LOCAL RULE 7.1 CERTIFICATION
`
`I hereby certify pursuant to Local Rule 7.1(a)(2) that counsel for Teva conferred with
`opposing counsel regarding the relief requested herein and opposing counsel assents to this
`motion.
`
`/s/ Robert Frederickson III
`
`CERTIFICATE OF SERVICE
`I, Robert Frederickson III, 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 20, 2018.
`
`/s/ Robert Frederickson III
`
`4
`
`
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