`Case 2:13-cv-00391-ES-JAD Document 65 Filed 06/19/14 Page 1 of 2 PageID: 676
`
`
`
`Charles M. Lizza
`
`Phone: (973)286-6715
`
`Fax:
`
`(973)286-6815
`
`c1izza@saul.com
`www.saul.c0m
`
`June 19, 2014
`
`VIA ECF AND FEDEX
`
`Hon. Joseph A. Dickson, U.S.M.J.
`United States District Court
`
`District of New Jersey
`Martin Luther King, Jr. Federal Courthouse
`50 Walnut Street
`
`Newark, New Jersey 07101
`
`_R_e:
`
`Jazz Pharmaceuticals, Inc. v. Amneal Pharmaceuticals, LLC, et al.
`Civil Action No. 13-391 (ES )1 JAD )1 Consolidated)
`
`Dear Judge Dickson:
`
`This firm, together with Quinn Emanuel Urquhart & Sullivan and Richard G. Greco PC,
`represents Plaintiff Jazz Pharmaceuticals, Inc. (“Jazz”) in the above-referenced consolidated
`action.
`
`Pursuant to the consolidated case schedule, we are to submit a proposed Discovery
`Confidentiality Order (“DCO”) in this matter today. However, the parties are still negotiating a
`specific paragraph in the DCO and believe that some additional time to meet and confer might be
`helpful to achieving an agreement.
`
`Accordingly, we respectfully request an extension to Monday, June 23, 2014 to submit a
`proposed DCO to the Court. All parties consent to this request, and it will not result in any other
`changes to the schedule. If the parties are unable to agree following their meet and confer, a
`proposed DCO will be submitted to Your Honor containing competing paragraphs for the
`Court’s consideration.
`
`If this meets with the Court’s approval, we respectfully request that Your Honor sign the
`below form of endorsement and have it entered on the docket.
`
`One Riverfront Plaza 0 Newark, NJ 07102 0 Phone: (973) 286-6700 0 Fax: (973) 286-6800
`
`
`DELAWARE
`
`MARYLAND
`
`PENNSYLVANIA
`NEW YORK
`NEW JERSEY
`A DELAWARE LMTED LIABILITY PARTNERSI-HP
`
`WASHINGTON, DC
`
`
`
`
`
`
`
`Case 2:13-cv-00391-ES-JAD Document 65 Filed 06/19/14 Page 2 of 2 PageID: 677
`Case 2:13-cv-00391-ES-JAD Document 65 Filed 06/19/14 Page 2 of 2 PageID: 677
`
`Hon. Joseph A. Dickson, U.S.M.J.
`June 19, 2014
`Page 2
`
`We thank the Court for its kind attention to this matter.
`
`Respectfully yours,
`
`Charles M. Lizza
`
`cc:
`
`All Counsel (Via e-mail)
`
`SO ORDERED:
`
`Hon. Joseph A. Dickson, U.S.M.J.
`
`
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