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`Case 2:13-cv-00391-ES-JAD Document 370 Filed 07/24/17 Page 1 of 2 PageID: 7194
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`VIA ECF & FEDEX
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`The Honorable Joseph A. Dickson, U.S.M.J.
`United States District Court
`
`Martin Luther King, Jr. Federal Building
`50 Walnut Street
`
`Newark, New Jersey 07102
`
`Charles M.Lizza
`
`Phone: (973)286-6715
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`Fax: (973) 286-686
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`clizza@saul.com
`wwwsaulcom
`
`July 20, 2017
`
`Re:
`
`Jazz Pharmaceuticals, Inc. v. Amneal Pharmaceuticals LLC. et al.
`Civil Action No. 13-391 (ES ngAD)
`
`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.
`
`The parties have been working diligently to complete fact discovery and resolve
`numerous disputes without the need for the Court’s intervention. Nevertheless, because of the
`number of parties involved and the remaining outstanding discovery issues, the parties believe
`that some additional time will be necessary 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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`r:-. .
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`Openingflpert Keats
`Rebuttal Exert Reorts
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`said
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`Dis ositive Motions _
`Pretrial Submissions
`48 hours before Pretrial
`48 hours before Pretrial
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`Conference
`Conference
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`‘ The parties agree that, if the Court does not issue a Markman decision by August 23, 2017, then they will meet and
`confer to submit ajoint proposal (if an agreement can be reached), or competing proposals (if no agreement can be
`reached). to the Court concerning an appropriate extension ofexpert discovery deadlines by August 30th.
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`Case 2:13-cv-00391-ES-JAD Document 370 Filed 07/24/17 Page 2 of 2 PageID: 7195
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`Case 2:13-cv-00391-ES-JAD Document 370 Filed 07/24/17 Page 2 of 2 PageID: 7195
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`July 20, 2017
`Page 2
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`TBD
`Pretrial Conference
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`_ Trial
`TBD
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`TBD
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`As Your Honor can see, the parties’ agreed-upon schedule will result in only a little more
`than a two-month overall extension ofthe schedule, which we believe is reasonable in light of
`the numerous complex issues involved. If this schedule meets with Your Honor’s approval, the
`parties respectfqu request that Your Honor sign the below form of endorsement and have it
`entered on the docket.
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`Thank you for Your Honor’s kind attention to this matter.
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`R pectfu ly yours,
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`
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`Charles M. Lizza
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`Lt,
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`All Counsel (via e-mzig)
`cc:
`so ORDERED on this A“? day 01%: ,3“
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`, 2017
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`Hon. JgsepiA. Dickson, U.S.M.J.
`
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