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`June 14, 2017
`
`VIA ECF
`
`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, NJ 07102
`
`Re:
`
`Jazz Pharmaceuticals, Inc. v. Amneal Pharmaceuticals LLC, et al.
`Civil Action No. 13-391 (ES)(JAD)
`
`Dear Judge Dickson:
`
`This firm represents defendant-counterclaimants Wockhardt Bio AG, Wockhardt USA
`LLC, and Wockhardt Ltd. (collectively, “Wockhardt”) in the action numbered 13-391 and 16-99.
`Jazz and Wockhardt resolved their claims, defenses, and counterclaims via a settlement. The
`District Court so-ordered the Stipulated Order of Dismissal on April 25, 2016 (D.I. 271).
`
`On June 13, 2017, Jazz filed an opposition letter (D.I. 363) to the letter dated May 26, 2017
`(D.I. 354) submitted by Lupin which is seeking an order compelling Jazz to produce the settlement
`and license agreements with Roxane, Wockhardt, and Ranbaxy relating to Xyrem along with all
`draft settlement agreements term sheets, and communications. Wockhardt opposes this request.
`For the reasons stated in Jazz’s letter dated June 13, 2017, Wockhardt joins in Jazz’s opposition to
`the production of these documents. Wockardt respectfully requests that the Court deny Lupin’s
`request and not order the confidential documents produced.
`
`Respectfully submitted,
`
`/s/ Sheila Raftery Wiggins
`
`Sheila Raftery Wiggins
`
`DUANE MORRIS LLP A DELAWARE LIMITED LIABILITY PARTNERSHIP
`ONE RIVERFRONT PLAZA, 1037 RAYMOND BLVD., SUITE 1800
`NEWARK, NJ 07102-5429
`DM2\7920314.1
`
`GREGORY R. HAWORTH, RESIDENT PARTNER
`PHONE: +1 973 424 2000 FAX: +1 973 424 2001
`
`
`
`Case 2:13-cv-00391-ES-JAD Document 364 Filed 06/14/17 Page 2 of 2 PageID: 7160
`
`
`
`
`
`June 14, 2017
`Page 2
`
`SRW/da
`cc: All counsel of record (via ECF)
`
`DM2\7920314.1
`
`
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