`
`Lerner David
`
`INTELLECTUAL PROPERTY LAW
`
`Lerner David Litteriberg
`Krumholz & Mantllk LLP
`60Q South Avenue West
`We&tfield NJ 07090
`900 654 5000 maio
`lemerdavld.com
`
`Paul IL Kochanski
`908.518.6314
`pkoehanski@lernetdavid.com
`
`June 7, 2016
`
`Document Filed Electronically
`
`Honorable Joseph A. Dickson, U.S.M.J.
`United States District Court
`District of New Jersey
`Martin Luther King, Jr. Bldg. & U.S. Courthouse
`50 Walnut Street
`Newark, New Jersey 07101
`
`Re:
`
`Jazz Pha?maceuticals, Inc. v. Amneal Pharmaceutictils LLC, et Cl/.
`Civil Action No. 13-cv-391 .. ES·JAD (consolidated)
`
`Dear Judge Dickson,
`
`I, along with Maddo!X Edwards, PLLC, represent Defendant Amneal Pharmaceuticals,
`LLC {"Amneal) in the above-referenced matter. We write on behalf of all parties to
`respectfully request a modification to the claim construction phase of the case schedule.
`
`In light of the Court's recent Order granting Plaintiffs extension to serve its Infringement
`Contentions and Responses to Defendant's Invalidity Contentions on August 12) 2016 (ECF No.
`293), the parties have agreed to modify the claim construction schedule to begin after the
`Plaintiff has served its Contentions.
`·
`
`Accordingly, all parties have consented to the following proposed modification to the
`claim construction phase of the current case schedule (ECF No. 215):
`
`Event
`
`Current Scheduling Order
`(ECF No. 215)
`
`Parties' Proposed
`Revised Schedule
`
`Parties exchange proposed
`terms for construction.
`L. Pat. R. 4.l(a)
`
`Parties exchange preliminary
`proposed constructions and
`identification of intrinsic and
`extrinsic evidence.
`L. Pat. R. 4.2(a)-(b)
`
`4566708_ l .docx
`
`June 10, 2016
`
`August 26, 2016
`
`July 1, 2016
`
`September 9, 2016
`
`
`
`Case 2:13-cv-00391-ES-JAD Document 301 Filed 06/08/16 Page 2 of 3 PageID: 5489
`
`tm LernerDavid
`
`INTEt.l.ECTUAl.. PROPERTY LAW
`
`Honorable Joseph A. Dickson, U.S.M.J.
`June7, 2016
`Page2
`
`Event
`
`Parties exchange evidence
`opposing any proposed claim
`construction.
`L. Pat R. 4.2(c)
`
`Parties complete fact
`discovery relating to claim
`construction.
`L. Pat. R. 4.4
`Parties file their Joint Claim
`Construction and Prehearing
`Statement.
`L. Pat. R. 4.3(a)-(e)
`
`Parties file and serve their
`opening Mcrrkman
`submissions.
`L. Pat. R. 4.5(a)
`
`Parties shall complete expert
`discovery pertaining to
`Markman issues.
`
`Parties :file and serve their
`responding Markman
`submissions.
`
`Parties shall submit to the
`Court a proposed schedule for
`a Markman hearing.
`
`Markman hearing
`
`Current Scheduling Order
`(ECF No. 215)
`
`Parties' Proposed
`Revised Schedule
`
`July 15, 2016
`
`September 23, 2016
`
`August 1, 2016
`
`October 7, 2016
`
`August 3, 2016
`
`October 10, 1016
`
`September 16, 2016
`
`November 4, 2016
`
`October 19, 2016
`
`December 2, 2016
`
`November 2, 2016
`
`December 16, 2016
`
`November 30, 2016
`
`Decembet 22, 2016
`
`To be determined
`
`To be determined
`
`If the Parties' proposed schedule modification meets with Your Honor's approval, we
`respectfully request that Your Honor sign the below form of endorsement and have it entered on
`the docket
`
`4566 708_ l .docx
`
`
`
`Case 2:13-cv-00391-ES-JAD Document 301 Filed 06/08/16 Page 3 of 3 PageID: 5490
`
`ILIB LernerDavid
`
`INTELLECTUAL Pl'IOPERTY LAW
`
`HonorableJosephA. Dickson, U.S.M.J.
`June 7, 2016
`Page3
`
`We thank the Court for its attention to this matter.
`
`Respectfully submitted,
`
`LERNER, DAVID, LITTENBERO,
`KRUMHOLZ & MENTLIK, LLP
`
`0
`
`PHK/pk
`cc:
`All Counsel of Record (via e•mail)
`
`SO ORDERED:
`
`456670&_! ,docic
`
`
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