`Case 2:13-cv-00391-ES-JAD Document 65 Filed 06/19/14 Page 1 of 2 PageiD: 676
`
`SaulEwipg
`
`CharlesM.
`
`Phone: (973) 286·
`Fax: (973) 286-
`
`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
`
`Re: Jazz Pharmaceuticals, Inc. v. Amneal Pharmaceuticals, LLC, et al.
`Civil Action No. 13-391 (ES)(JAD)(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 nco 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 nco 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 • Newark, NJ 07102 • Phone: (973) 286-6700 • Fax: (973) 286-6800
`
`DELAWARE
`
`MARYLAND
`
`NEW 1ERSEY
`
`NEW YORK
`
`PENNSYLVANIA
`
`WASHINGTON, DC
`
`ADELAWAIU!LIMITEDUABIUTYPAR.TNERSHIP
`
`
`
`Case 2:13-cv-00391-ES-JAD Document 67 Filed 06/20/14 Page 2 of 2 PageID: 686
`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
`Page2
`
`We thank the Court for its kind attention to this matter.
`
`Respectfully yours,
`
`Charles M. Lizza
`
`cc:
`
`All Counsel (via e-mail)
`
`SO ORDERED:
`
`~~
`
`
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