`
`CRITCHLEY, KINUM & VAZQUEZ, LLC
`By: John Michael Vazquez, Esq.
`75 Livingston Avenue
`Roseland, NJ 07068
`Telephone: (973) 422-9200
`
`Attorney for Defendants Agila Specialties Private Limited and
`Agila Specialties Inc. f/k/a Strides Inc.
`
`McELROY, DEUTSCH, MULVANEY & CARPENTER, LLP
`By: George H. Parsells, III, Esq.
`Michael Rato, Esq.
`1300 Mount Kemble Avenue
`P.O. Box 2075
`Morristown, NJ 07962
`Phone: (973) 993-8100
`
`Attorneys for Defendant Sagent Pharmaceuticals, Inc.
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF NEW JERSEY
`
`BAXTER HEALTHCARE CORPORATION, BAXTER
`INTERNATIONAL INC., and BAXTER HEALTHCARE
`S.A.,
`
`Plaintiffs,
`
`v.
`
`Docket No.:
`1:13-cv-6228-JBS-KMW
`
`HQ SPECIALTY PHARMA CORPORATION,
`WELGRACE RESEARCH GROUP, ESTATE OF
`GEORGE OWOO, and JANET FENNING-OWOO, in
`her capacity as INDEPENDENT ADMINISTRATOR OF
`THE ESTATE OF GEORGE OWOO and as VICE
`PRESIDENT OF WELGRACE RESEARCH GROUP,
`
`Defendants.
`
`BAXTER HEALTHCARE CORPORATION, BAXTER
`INTERNATIONAL INC., and BAXTER HEALTHCARE
`S.A.,
`
`Plaintiffs,
`
`v.
`
`Docket No.:
`1:14-cv-07094-JBS-JS
`
`
`
`Case 1:15-cv-01684-JBS-JS Document 33 Filed 05/27/15 Page 2 of 3 PageID: 204
`
`AGILA SPECIALTIES PRIVATE LIMITED and AGILA
`SPECIALTIES INC. f/k/a STRIDES INC.,
`
`Defendants.
`
`BAXTER HEALTHCARE CORPORATION, BAXTER
`INTERNATIONAL INC., and BAXTER HEALTHCARE
`S.A.,
`
`Plaintiffs,
`
`v.
`
`SAGENT PHARMACEUTICALS, INC.,
`Defendant.
`
`Docket No.:
`1:15-cv-01684-JBS-JS
`
`NOTICE OF MOTION TO CONSOLIDATE PURSUANT TO FEDERAL RULE OF
`CIVIL PROCEDURE 42 AND LOCAL CIVIL RULE 42.1
`
`To:
`
`Robert D. Rhoad
`Dechert LLP
`902 Carnegie Center, Suite 500
`Princeton, New Jersey 08540-6531
`
`Arnold B. Calmann, Esq.
`Jeffrey Soos, Esq.
`Katherine A. Escanlar, Esq.
`Saiber LLC
`One Gateway Center, 10th Floor
`Newark, NJ 07102-5311
`
`Clifford M. Davidson, Esq.
`Davidson, Davidson & Kappel, LLC
`485 Seventh Avenue, 14th Floor
`New York, NY 10018
`
`PLEASE TAKE NOTICE that on July 6, 2015, at 9:00 a.m. or as soon thereafter as
`
`counsel may be heard, pursuant to L.Civ.R. 101.1(c), the undersigned attorneys for Defendants
`
`Agila Specialties Private Limited and Agila Specialties Inc. as well as Defendants Sagent
`
`Pharmaceuticals, Inc. (collectively “Defendants”), shall move pursuant to Fed. R. Civ. Pro. 42
`
`2
`
`
`
`Case 1:15-cv-01684-JBS-JS Document 33 Filed 05/27/15 Page 3 of 3 PageID: 205
`
`and D.N.J. Local Civil Rule 42.1 before the United States District Court, District of New Jersey,
`
`Cohen United States Courthouse, 1 John F. Gerry Plaza, 4th and Cooper Streets, Camden, New
`
`Jersey, for entry of an Order consolidating Defendants’ matters with Baxter Healthcare Corp. et
`
`al. v. HQ Specialty Pharma et al., Case No. 13-cv-06228 (D.N.J.) for purposes of claim
`
`construction and trial. Please note that Defendants have requested an expedited return date on
`
`the motion which, if granted by the Court, will modify the return date stated above.
`
`PLEASE TAKE FURTHER NOTICE that in support of the motion, the Defendants
`
`shall rely on the accompanying legal brief.
`
`A proposed form of Order submitted for the Court’s convenience.
`
`/s/ John Michael Vazquez
`John Michael Vazquez, Esq.
`CRITCHLEY, KINUM & VAZQUEZ, LLC
`75 Livingston Avenue
`Roseland, New Jersey 07068
`(973) 422-9200
`
`Attorney for Defendants Agila Specialties Private
`Limited and Agila Specialties Inc.
`
`_
`
`/s/ Michael Rato
`George H. Parsells, III
`Michael Rato
`McElroy, Deutsch, Mulvaney & Carpenter, LLP
`1300 Mount Kemble Avenue
`P.O. Box 2075
`Morristown, NJ 07962
`Phone: (973) 993-8100
`Fax: (973) 425-0161
`gparsells@mdmc-law.com
`mrato@mdmc-law.com
`
`Attorneys for Defendant Sagent Pharmaceuticals
`Inc.
`
`Dated: May 27, 2015
`
`3
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