`
`Case 2:13-cv-00391-ES-JAD Document 398 Filed 10/10/17 Page 1 of 2 PageID: 7769
`
`CharlesM.Liua
`Phone: (973) 286-6715
`
`Fax: (973) 286-6815
`clizzn@saul.com
`www.muleom
`
`October 6, 2017
`
`SAUL EWING
`
`
`A R N ST El N
`
`
`& L EH R LLP
`
`VIA ECF
`
`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
`
`3;:
`
`Jazz Pharmaceuticals, Inc. v. Amneal Pharmaceuticals LLC, et al.,
`Civil Action No. 13-391 (ESMAD)
`
`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. 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:
`
`~
`.._.t
`
`l
`
`
`
`
`
`
`
`I
`I
`I
`..l Iflmth
`November 3, 2017
`September 26, 2017
`Close of Fact Discovery
`December 8, 2017
`November 7, 2017
`I . nin; Exert Re norts
`February 9, 2018
`Jan -
`9, 2018
`Rebuttal Ex-ert R orts
`
`
`February 13, 2018
`March 16, 2018
`R .1 Ex-ert Reorts
`
`March 27, 2018
`A ril 27, 2018
`Close of Exert Discove
`
`__I_
`
`
`Pretrial Submissions
`48 hours before Pretrial
`48 hours before Pretrial
`
`‘ The parties agree that, if the Court does not issue a Markman decision by November 3, 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 of expert discovery deadlines by November 10, 2017.
`
`
`
`Case 2:13-cv-00391-ES-JAD Document 398 Filed 10/10/17 Page 2 of 2 PageID: 7770
`
`Case 2:13-cv-00391-ES—JAD Document 398 Filed 10/10/17 Page 2 of 2 PagelD: 7770
`
`Hon. Joseph A. Dickson, U.S.M.J.
`October 6, 2017
`Page 2
`
`
`
`
`
`Conference
`
`Pretrial Conference
`TBD
`Trial
`TBD
`
`As Your Honor can see, the parties’ agreed-upon schedule will result in only a little more
`than a one-month overall extension of the 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 respectftu 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.
`
`Res
`
`lly yours,
`
`til/L.
`
`Charles M. Lizza
`
`cc:
`
`All Counsel (via e-mail)
`*8
`so ORDERED on thisEday of get- , 2017:
`
`Hon. %selghA.Dickson,U.S.M.J.
`
`
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