`
`
`
` CARELLA, BYRNE, CECCHI, OLSTEIN, BRODY & AGNELLO, P.C.
`COUNSELLORS AT LAW
`_____________
`
`5 BECKER FARM ROAD
`ROSELAND, N.J. 07068 -1739
`PHONE (973) 994 -1700
`FAX (973) 994 -1744
`www.carellabyrne.com
`
`CHARLES C. CARELLA
`
`BRENDAN T. BYRNE
`
`PETER G. STEWART
`
`JAN ALAN BRODY
`
`JOHN M. AGNELLO
`
`CHARLES M. CARELLA
`
`JAMES E. CECCHI
`
`
`
`
`
`
`
`
`
`
`
`JOHN G. GILFILLAN III (1936-2008)
`ELLIOT M. OLSTEIN (1939-2014)
`
`JAMES D. CECCHI (1933-1995)
`
`JAMES T. BYERS
`
`DONALD F. MICELI
`
`A. RICHARD ROSS
`
`CARL R. WOODWARD, III
`
`MELISSA E. FLAX
`
`DAVID G. GILFILLAN
`
`G. GLENNON TROUBLEFIELD
`
`BRIAN H. FENLON
`
`LINDSEY H. TAYLOR
`
`CAROLINE F. BARTLETT
`
`
`
`May 30, 2017
`
` FRANCIS C. HAND
`
` AVRAM S. EULE
`
` CHRISTOPHER H. WESTRICK*
`
` ______
`
` OF COUNSEL
`
`
`
` *CERTIFIED BY THE SUPREME COURT OF
`
` NEW JERSEY AS A CIVIL TRIAL ATTORNEY
`
`RAYMOND J. LILLIE
`
`WILLIAM SQUIRE
`
`STEPHEN R. DANEK
`
`DONALD A. ECKLUND
`
`MEGAN A. NATALE
`
`ZACHARY S. BOWER+
`
`MICHAEL CROSS
`
`CHRISTOPHER J. BUGGY
`
`JOHN V. KELLY III
`
`MICHAEL A. INNES
`
`+MEMBER FL BAR ONLY
`
`
`
`
`
`
`
`
`
`RE:
`
`
`Jazz Pharmaceuticals, Inc., et al. v. Amneal Pharmaceuticals, LLC, et al.
`Civil Action No. 2:13-cv-391 (ES)(JAD) (Consolidated)
`
`
`
`Via ECF
`Hon. Joseph A. Dickson, U.S.M.J.
`United States District Court for the District of New Jersey
`Martin Luther King, Jr. Federal Building & U.S. Courthouse
`50 Walnut Street
`Newark, New Jersey 07101
`
`
`
`
`
`
`Dear Judge Dickson:
`
`This Firm, together with Rakoczy Molino Mazzochi Siwik LLP, represents Lupin
`
`Limited, Lupin Pharmaceuticals, Inc. and Lupin Inc. (collectively, “Lupin”) in the above
`consolidated matter.
`
`We write to request that the May 26, 2017 letter from Melissa E. Flax to Your Honor
`
`(D.I. 354) be unsealed as we have confirmed with counsel for Plaintiffs that it does not contain
`any of Plaintiffs’ confidential information requiring that it be under seal. However, Exhibits 2
`and 8 to the May 26, 2017 letter (D.I. 354-1 and 354-2, respectively) do contain Plaintiffs’
`confidential information and should remain under seal. An appropriate motion to seal will be
`filed with respect to D.I. 354-1 and 354-2 in accordance with the Local Rules.
`
`If the foregoing is acceptable to Your Honor, it is respectfully requested that this letter be
`
`“So Ordered” and the Clerk be directed to unseal D.I. 354.
`
`Respectfully submitted,
`
`CARELLA, BYRNE, CECCHI,
`OLSTEIN, BRODY & AGNELLO
`
`/s/ Michael Cross
`
`MICHAEL CROSS
`
`
`cc:
`
`Counsel of Record (via e-mail)
`
`
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