`','\
`Saul Ewing
`
`Charles M. Lizza
`Phone: (973) 286-671 S
`Fax: (973) 286-6815
`clizza@saul.com
`www.saul.com
`
`\-
`
`- - - - - ---
`
`VIAECF
`
`The Honorable Douglas E. Arpert, U.S.M.J.
`United States District Court
`Clarkson S. Fisher Building & U.S. Courthouse
`402 East State Street
`Trenton, NJ 08608
`
`Re: Helsinn Healthcare S.A., et al. v. Teva Pharmaceuticals USA, Inc., et al.
`Civil Action No. 15-8663 (MLC)fDEA)
`
`Dear Judge Arpert:
`
`This firm, together with Paul Hastings LLP and Loeb & Loeb LLP, represents Plaintiffs.
`in the above-referenced matter. We write jointly with defendants Teva Pharmaceuticals USA,
`Inc. and Teva Pharmaceutical Industries, Ltd. (collectively, "Teva") to request an adjournment of
`the Rule 16 conference scheduled for March 29, 2016 (D.I. 17) and a stay of this matter pending
`the results of Teva's appeal in a related action.
`
`As Your Honor is aware, the parties to this action were also parties to Civil Action No.
`11-3962, which resulted in a Final Judgment in favor of Plaintiffs on November 13, 2015. (C.A.
`11-3962, D.I. 361.) Teva has appealed Judge Cooper's decision in that action, and the appeal is
`currently pending before the Federal Circuit as Appeal No. 2016-1284 ("the ANDA appeal").
`The parties believe that the Federal Circuit's decision on the ANDA appeal may either
`streamline the disputed issues or obviate the need for further proceedings in this action.
`Accordingly, the parties respectfully request that Your Honor stay this action pending a decision
`from the Federal Circuit in the ANDA appeal. The parties further propose that the parties notify
`the Court within one week of the issuance of a mandate from the Federal Circuit on the ANDA
`appeal. If this meets with Your Honor's approval, we respectfully 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.
`
`One Riverfront Plaza,.Suite 1520 •Newark, NJ 07102-5426 • Phone:.(973) 28~·6700 + Fn:.: (973) 286-6JQQ
`
`DELAWARE MARYLAND MASSACHUSETTS
`
`NEW JERSEY
`
`NEW YORK
`
`PENNSYLVANIA WASHINGTON, DC
`
`A DELAWARE LIMITED LIABILITY PARTNERSHIP
`
`
`
`Case 3:15-cv-08663-MLC-DEA Document 22 Filed 03/24/16 Page 2 of 2 PageID: 72
`Hon. Douglas E. Arpert, U.S.M.J.
`:er· March 21, 2016
`\ Page 2
`
`~-
`
`Respectfully yours,
`
`. s/ Mayra.\l.Tarantino
`Mayra V. Tarantino
`
`On behalf of Defendants
`
`cc::
`
`Hon. Mary L. Cooper, U.S.D.Ji
`All Counsel (via e-mail)
`
`Charles M. Lizza
`
`On behalf of Plaintiffs
`
`This action is hereby STAYED pending a decision from the Federal Circuit on Appeal No. 2016-
`1284. The March 29, 2016 Rule 16 conference is hereby adjourned, and the parties need not
`submit a Joint Discovery Plan at this time. The parties are ordered to notify the Court within one
`week of the issuance of a mandate from the Federal Circuit on Appeal No. 2016-1284.
`
`ert, U.S.M.J •.
`
`
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