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`Case 2:13-cv-00391-ES-JAD Document 340 Filed 02/27/17 Page 1 of 2 PageID: 6925
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`
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`Charles M. Lizza
`
`Phone: (973)286-6715
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`Fax: (973) 286-6815
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`clizza@saul.com
`www.5aul.com
`
`February 24, 2017
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`VIA ECF & FEDEX
`
`The Honorable Joseph A. Dickson, U.S.M.J.
`United States District Court
`
`Martin Luther King, Jr. Federal Building
`50 Walnut Street, Room 2060
`
`Newark, New Jersey 07102
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`E:
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`Jazz Pharmaceuticals, Inc. v. Amneal Pharmaceuticals LLC, et al.
`Civil Action No. 13-391 (ESKJAD)
`
`Dear Judge Dickson:
`
`This firm, together with Quinn Emanuel Urquhart & Sullivan, LLP and Richard G. Greco
`PC, represents plaintiffs Jazz Pharmaceuticals, Inc. and Jazz Pharmaceuticals Ireland Limited
`(collectively, “Jazz”) in the above-captioned action. We write on behalf of all parties.
`
`Jazz and the Defendants have been working diligently to complete fact discovery and
`resolve numerous disputes without the need for court intervention. Nevertheless, because of the
`number of parties involved and the remaining outstanding discovery issues, the parties believe
`that some additional time will be required to complete fact discovery and, ultimately, prepare this
`case for trial. Accordingly, the parties have agreed, subject to Your Honor’s approval, to the
`following modifications to the current case schedule:
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`.
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`Event
`Close of Fact Discove
`Oenin Exert Reorts
`Rebuttal Ex ert Reorts
`Rel Exert Reorts
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`Discove
`Disositive Motions
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`
`
`Pro: I sed Revised Date
`une 23, 2017
`111 24, 2017
`etember 25, 2017
`ctober 25, 2017
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`For!) ao‘a‘c‘aH 00 No p—t \1
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`Conference
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`onference
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`Pretrial Submissions ‘ 8 hours before Pretrial
`Pretrial Conference
`Trial
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`One Riverfront Plaza, Suite [520 0 Newark, NJ 07l02-5426 0 Phone: (973) 286-6700 o Fax: (973) 286-6800
`DELAWARE
`MARYLAND
`MASSACHUSETTS
`NEW JERSEY
`NEW YORK
`PENNSYLVANIA WASHINGTON. DC
`
`
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`Case 2:13-cv-00391-ES-JAD Document 340 Filed 02/27/17 Page 2 of 2 PageID: 6926
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`
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`Case 2:13-cv-00391-ES-JAD Document 340 Filed 02/27/17 Page 2 of 2 PageID: 6926
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`Hon. Joseph A. Dickson, U.S.M.J.
`February 24, 2017
`Page 2
`
`As Your Honor can see, the parties’ agreed-upon schedule will result in only a two-month
`overall extension of the schedule, which we believe is reasonable in light of the numerous
`complex issues involved and the intervening May trial scheduled in the Roxane case. If this
`schedule meets with Your Honor’s approval, the parties respectfully request that Your Honor
`sign the below form of endorsement and have it entered on the docket.
`
`Thank you for Your Honor’s kind attention to this matter.
`
`Respectfully yours,
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`Charles M. Lizza
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`cc:
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`All Counsel (via e-mail)
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`SO ORDERED:
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` A\§~x\\><
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`Hon. J seph A. Dickson, U.S.M.J.
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`The (cu/“i— Clarhbles ‘H‘ch l" “dofi-ly +le cheJule) ,‘+ is
`
`{lo-l adjourm’xy
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`‘Hic Maf‘Kmm bearlnj Schedulfli For April 7) (am-7
`
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