`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`
`Kowa Company, Ltd.,
`Kowa Pharmaceuticals America, Inc., and
`Nissan Chemical Industries, Ltd.,
`
`Plaintiffs,
`
`v.
`
`Aurobindo Pharma Limited and
`Aurobindo Pharma USA Inc.,
`
`Defendants.
`
`Kowa Company, Ltd.,
`Kowa Pharmaceuticals America, Inc., and
`Nissan Chemical Industries, Ltd.,
`
`Plaintiffs,
`
`v.
`
`Amneal Pharmaceuticals, LLC,
`
`Defendants.
`
`Kowa Company, Ltd.,
`Kowa Pharmaceuticals America, Inc., and
`Nissan Chemical Industries, Ltd.,
`
`Plaintiffs,
`
`v.
`
`Mylan Inc. and Mylan Pharmaceuticals
`Inc.,
`
`Defendants.
`
`1
`
`Civil Action No. 14-CV-2497 (PAC)
`
`Civil Action No. 14-CV-2758 (PAC)
`
`Civil Action No. 14-CV-2647 (PAC)
`
`
`
`Case 1:14-cv-02758-PAC Document 24 Filed 10/03/14 Page 2 of 16
`
`Kowa Company, Ltd.,
`Kowa Pharmaceuticals America, Inc., and
`Nissan Chemical Industries, Ltd.,
`
`Plaintiffs,
`
`v.
`
`Zydus Pharmaceuticals (USA) Inc., and
`Cadila Healthcare Ltd. (dba Zydus Cadila),
`
`Defendants.
`
`Kowa Company, Ltd.,
`Kowa Pharmaceuticals America, Inc., and
`Nissan Chemical Industries, Ltd.,
`
`Plaintiffs,
`
`v.
`
`Orient Pharma Co., Ltd.,
`
`Defendants.
`
`Kowa Company, Ltd.,
`Kowa Pharmaceuticals America, Inc., and
`Nissan Chemical Industries, Ltd.,
`
`Plaintiffs,
`
`v.
`
`Sawai USA, Inc., and
`Sawai Pharmaceutical Co., Ltd.,
`
`Defendants.
`
`Civil Action No. 14-CV-2760 (PAC)
`
`Civil Action No. 14-CV-2759 (PAC)
`
`Civil Action No. 14-CV-5575 (PAC)
`
`CIVIL CASE MANAGEMENT PLAN AND SCHEDULING ORDER
`
`This Civil Case Management Plan, submitted in accordance with Rule 26(f), Fed.
`R. Civ. P., is adopted as the Scheduling Order of this Court in accordance with Rule
`
`2
`
`
`
`Case 1:14-cv-02758-PAC Document 24 Filed 10/03/14 Page 3 of 16
`
`16(f), Fed. R. Civ. P.
`
`All parties do not consent to conducting all further proceedings before a
`Magistrate Judge, including motions and trial. 28 U.S.C. § 636(c).
`
`This case is not to be tried to a jury.
`
`Defendants’ Proposal: Parties may file amended pleadings or additional parties
`may be joined without leave of the Court on or before May 11, 2015.
`
`Plaintiffs’ Proposal: Parties may file amended pleadings or additional parties
`may be joined without leave of the Court on or before February 15, 2015.
`
`Amended pleadings may not be filed and additional parties may not be joined
`thereafter without leave of Court.
`
`Initial disclosures pursuant to Rules 26(a)(1), Fed. R. Civ. P., shall be completed no
`later than October 20, 2014.
`
`All fact discovery shall be completed no later than October 5, 2015.
`
`The parties are to conduct discovery in accordance with the Federal Rules of
`Civil Procedure and the Local Rules of the Southern District of New York. The
`following interim deadlines may be extended by the written consent of all parties
`without application to the Court, provided all fact discovery is completed by the
`date set forth in paragraph 5 above:
`
`a.
`
`b.
`
`Initial requests for production of documents to be served not later than
`November 20, 2014.
`
`Defendants’ Proposal:
`
`Document production of documents written in a foreign language shall be
`substantially complete by no later than February 5, 2015; document
`production of documents written in the English language shall be
`substantially complete by no later than March 27, 2015. Until a protective
`order is entered in this case, all documents and translations produced will
`be produced and maintained on an “outside attorney’s eyes only” basis.
`
`Plaintiffs’ Proposal:
`
`This provision is not necessary. Document production will be ongoing in
`good faith during fact discovery. Alternatively, plaintiffs propose the
`following alternative: Document production shall be substantially
`complete by June 5, 2015.
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`3
`
`
`
`Case 1:14-cv-02758-PAC Document 24 Filed 10/03/14 Page 4 of 16
`
`Protective Order:
`
`The parties shall propose a protective order to the Court on or before
`November 20, 2014. Documents to be produced will be produced in
`accordance with the Protective Order adopted by the Court.
`
`c.
`
`Interrogatories to be served not later than September 4, 2015. The parties
`may commence serving Local Civil Rule 33.3(a) interrogatories on
`October 20, 2014. Defendants shall be permitted to serve up to 25 joint
`interrogatories on Plaintiffs. In addition, each Defendant shall be
`permitted to serve up to 10 individual interrogatories on Plaintiffs.
`Plaintiffs shall be permitted to serve up to 25 interrogatories on each
`Defendant (for clarity, e.g., Mylan Inc. and Mylan Pharmaceuticals Inc.
`shall be treated collectively as a single Defendant).
`
`Defendants’ Position:
`
`Defendants believe that there is discrete factual information in Plaintiffs’
`possession, and which particularly will not require a need for later
`supplementation, that will bear on its invalidity defenses, such that an
`interrogatory is the most efficient means to secure the information (e.g.,
`the circumstances relating to the conception of the invention(s) alleged in
`the asserted patents (and the date of such conception); and the reduction
`to practice of such invention; the basis for Plaintiffs’ assertion that a
`particular party has standing to assert a patent at the time the Complaint
`was filed). Defendants likewise recognize that Plaintiffs may determine
`that there is information regarding Defendants’ products as defined by the
`ANDA where it may be more efficient to secure an interrogatory response.
`In such circumstances, securing this information early may obviate the
`need for further avenues of discovery in the case and thus represent the
`most efficient way to secure the information.
`
`After the disclosure of Preliminary Infringement and Invalidity
`Contentions, the parties are permitted to serve contention interrogatories
`seeking information responsive to those Contentions (i.e., Defendants may
`serve an interrogatory seeking Plaintiffs’ contentions regarding issues
`related to validity, and Plaintiffs may serve an interrogatory seeking
`Defendants’ contentions regarding non-infringement).
`
`4
`
`
`
`Case 1:14-cv-02758-PAC Document 24 Filed 10/03/14 Page 5 of 16
`
`Plaintiffs’ Position:1
`
`Contention interrogatories shall comply with Local Rule 33.3(c).
`
`Depositions of fact witnesses to be completed by October 5, 2015.2
`
`Defendants’ Proposal:
`
`d.
`
`e.
`
`Requests to Admit shall be limited to 50 per party (and, e.g., the two
`Mylan defendants are to each be treated as a single party), to be served
`not later than September 30, 2015.
`
`Plaintiffs’ Position:
`
`Requests to Admit should be governed by Fed. R. Civ. P. 36, and should
`be served by no later than September 5, 2015.
`
`7.
`
`Expert Discovery:
`
`1 Plaintiffs note that this joint document is being submitted as a single, joint submission for the
`convenience of the Court. Plaintiffs note, though, that defendants have insisted on including
`various arguments on several topics, which plaintiffs do not believe are properly included in a
`proposed case management and discovery order. Rather than further unduly and prematurely
`burdening the Court, plaintiffs are refraining from including arguments on issues that plaintiffs
`do not believe are necessary or proper to include in a proposed case management and scheduling
`order.
`2 Defendants’ Additional Proposal: Defendants note that there are a large number of inventors
`listed on the asserted patents who reside in a foreign country and may testify in a foreign
`language. As the Court is undoubtedly aware, it is difficult to schedule witnesses for depositions
`overseas, particularly in Japan, where depositions for all U.S. litigation is restricted to one or two
`small rooms at the U.S. Embassy in Tokyo or Osaka. It is Defendants’ experience that a failure
`to meet and confer and resolve these issues very early in the case will result in delaying the
`schedule.
`(For example, there is no reason for the parties to wait to learn whether Plaintiffs’
`counsel represents the named inventors; and if so, whether the parties can reach agreement about
`whether the inventors will be deposed in the U.S.). These are issues that can be discussed now
`and need not wait for resolution. Thus, Defendants propose that the Court instruct Defendants
`and Plaintiffs to meet and confer regarding logistics and scheduling of depositions of witnesses
`who currently reside in a foreign country by no later than November 3, 2014, with a status report
`to be filed by November 7.
`If the parties are unable to agree on such provisions, Defendants
`expect to promptly ask the court for assistance with the foreign depositions.
`
`Plaintiffs’ Position: Singling out one aspect of complicated discovery is unnecessary and
`premature. Plaintiffs intend to cooperate in discovery and expect Defendants to do the same, and
`attempt to resolve any issues in good faith if and when they arise.
`
`5
`
`
`
`Case 1:14-cv-02758-PAC Document 24 Filed 10/03/14 Page 6 of 16
`
`Defendants’ Proposal:
`
`Defendants propose the following expert discovery schedule:
`
`a.
`
`All expert discovery shall be completed no later than March 11, 2016.
`
`Defendants’ Proposal:
`
`The parties’ opening expert reports (e.g., infringement and secondary
`considerations of non-obviousness for Plaintiffs; anticipation, prima facie
`case of obviousness, § 112, etc. for Defendants) shall be served by
`December 15, 2015. The parties’ responsive expert reports shall be served
`by January 29, 2016. The parties’ reply expert reports shall be served by
`February 15, 2016. Expert depositions shall conclude by March 11, 2016.
`
`Plaintiffs’ position:
`
`The parties’ opening expert reports on those issues on which they bear the
`burden of proof shall be served by December 15, 2015.3
`
`Defendants’ proposed sequence of expert discovery is otherwise
`acceptable to Plaintiffs, but Plaintiffs respectfully submit that Markman
`claim construction, if necessary, should follow expert discovery, with the
`deadlines adjusted accordingly.
`
`c.
`
`Defendants’ Additional Proposal:
`
`If a Markman ruling issues during or after the close of expert discovery,
`with a claim construction not originally contemplated by the parties, the
`parties shall have 10 days to submit supplemental reports reflecting any
`opinions changed, modified, or which otherwise require revision as a
`result of any Markman ruling, and shall promptly meet and confer on a
`deposition schedule, if necessary, with the scope of depositions limited to
`new matters raised by the claim construction ruling.
`
`Plaintiffs’ Position:
`
`Markman issues, if any, should be addressed after expert discovery.
`
`8.
`
`Markman Proceedings
`
`Defendants’ Proposal:
`
`3 The parties currently disagree as to which party has the burden of proof on certain issues, and
`plaintiffs are willing to work in good faith to resolve that disagreement.
`
`6
`
`
`
`Case 1:14-cv-02758-PAC Document 24 Filed 10/03/14 Page 7 of 16
`
`A Markman (claim construction) hearing shall be held, if necessary, to determine
`the meaning of any terms for the claims of the patents-in-suit, or to determine
`whether claim terms are indefinite, as follows:
`
`(i) no later than February 27, 2015, each party shall exchange a list of potentially
`disputed claim terms or terms deemed indefinite;
`
`(ii) no later than March 13, 2015 each party shall identify and exchange its
`proposed construction of all of
`the potentially disputed claim terms, or
`summarize in one paragraph why any asserted term is indefinite;
`
`(iii) no later than March 27, 2015 the parties shall meet and confer to discuss and
`analyze the proposed construction of the claim terms, if the parties have a claim-
`term dispute;
`
`(iv) no later than April 6, 2015, the parties shall jointly file a Joint Disputed Claim
`Terms Chart pursuant to Local Patent Rule 11
`
`(v) no later than May 6, 2015, Plaintiffs shall file their opening claim construction
`brief (including any supporting intrinsic and extrinsic evidence); and Defendants
`shall file their opening brief on claim construction and indefiniteness.
`
`(vi) no later than June 8, 2015, Plaintiffs and Defendants shall file their responsive
`claim construction brief(s) (including any rebuttal evidence that could not have
`been raised in the opening submission) and Plaintiffs shall file their response on
`indefiniteness;
`
`(vii) no later than June 15, 2015, Defendants shall file their indefiniteness reply
`(if any);
`
`(ix) the claim construction hearing shall be held at a date and time to be
`scheduled by the Court, preferably before August 31, 2015.
`
`Plaintiffs’ Position:
`
`Defendants’ proposed sequence of Markman events is acceptable to Plaintiffs,
`but Plaintiffs respectfully submit that Markman claim construction, if necessary,
`should follow expert discovery, with the deadlines adjusted accordingly.
`
`An indefiniteness defense is not a part of a Markman hearing.
`
`All motions and applications shall be governed by the Court’s Individual
`Practices, including pre-motion conference requirements.
`
`Counsel for Plaintiffs and Counsel for each Defendant must separately meet and
`confer for at least one hour per Defendant (with, e.g., the Mylan defendants to be
`
`9.
`
`10.
`
`7
`
`
`
`Case 1:14-cv-02758-PAC Document 24 Filed 10/03/14 Page 8 of 16
`
`treated collectively as a “Defendant”) to discuss settlement within fourteen (14)
`days following the close of fact discovery.
`
`11.
`
`a.
`
`Counsel for the parties have discussed an informal exchange of information
`in aid of an early settlement of this case and have agreed that settlement is
`highly unlikely at this early stage of the case.
`
`b.
`
`c.
`
`d.
`
`Counsel for the parties have discussed the use of the following alternative
`dispute resolution mechanisms for use in this case: (i) a settlement
`conference before a Magistrate Judge; (ii) participation in the District’s
`Mediation Program; and/or
`(iii)
`retention of a privately retained
`mediator. Counsel for the parties propose the following alternative
`dispute resolution mechanism for this case: The parties select a settlement
`conference before a Magistrate Judge.
`
`Counsel for the parties recommend that the alternate dispute resolution
`mechanism designated in Paragraph 11(b) herein, be employed at the
`following point in the case:
`thirty (30) days after the Court’s claim
`construction decision, if any, or conclusion of expert discovery, whichever
`event occurs earlier.
`
`The use of any alternative dispute resolution mechanism does not stay or
`modify any date in this Order.
`
`12. The Final Pretrial Submission Date shall be April 25, 2016.
`
`By the Final Pretrial Submission Date, the parties shall submit a Joint Pretrial Order
`prepared in accordance with the Court’s Individual Practices and Rule 26(a)(3), Fed.
`R. Civ. P. Any motions in limine (for which the pre-motion conference requirement
`is waived) shall be filed by the Final Pretrial Submission Date. Responsive briefs, if
`any, to said motions shall be filed 7 days after the Final Pretrial Submission Date.
`
`13. Counsel for the parties have conferred and their present best estimate of the length
`of trial is: 14 to 21 days.
`
`14. Summary of Civil Case Management Plan Scheduling Dates: Add any additional
`dates.
`
`Civil Case Management Plan Requirement
`Initial Disclosure pursuant to Rule 26(a)(1), Fed. R. Civ. P. to be
`served no later than:
`
`Dates:
`October 20, 2014
`
`8
`
`
`
`Case 1:14-cv-02758-PAC Document 24 Filed 10/03/14 Page 9 of 16
`
`Defendants’ proposal:
`Plaintiffs must serve Disclosure of Asserted Claims and
`Preliminary Infringement Contentions; see also paragraph 6(c)
`above.
`Plaintiffs’ position:
`Conform to local rules regarding contention interrogatories (L.R.
`33.3(c)).
`
`Defendants’ proposal:
`Defendants must serve Preliminary Invalidity Contentions; see
`also paragraph 6(c) above.
`Plaintiffs’ position:
`Conform to local rules regarding contention interrogatories (L.R.
`33.3(c)).
`
`December 5, 2014
`
`January 16, 2015
`
`All fact discovery to be completed no later than:
`
` Fact Discovery - initial requests for production of
`documents to be served no later than:
`
`October 5, 2015
`
`November 20, 2014
`
`Document Production:
`Defendants’ proposal:
` Fact Discovery – document production of documents
`written in a foreign language to be substantially complete
`by:
`
`February 5, 2015
`
` Fact Discovery - document production of documents in the
`English language to be substantially complete by:
`
`March 27, 2015
`
`Plaintiffs’ position:
`Document production shall be ongoing.
`If a document production deadline is to be set, it should be
`uniform and fair to all parties. In the event a deadline is set,
`Plaintiffs suggest: Document production shall be substantially
`complete by June 5, 2015:
`
` Fact Discovery - interrogatories (aside from those
`contemplated by Local Civil Rule 33.3(a)) to be served no
`later than:
`
`September 5, 2015
`
` Fact Discovery - requests to admit to be served no later
`than:
`
`September 5, 2015
`
`9
`
`
`
`Case 1:14-cv-02758-PAC Document 24 Filed 10/03/14 Page 10 of 16
`
` Fact Discovery - depositions of fact witnesses to be
`completed no later than:
`
`October 5, 2015
`
`Markman Proceedings
`
`Defendants’ proposal:
`
` Markman - each party shall exchange a list of potentially
`disputed or indefinite claim terms.
`
`February 27, 2015
`
` Markman - each party shall identify and exchange its
`proposed construction of all of the potentially disputed
`claim terms or indefiniteness summary.
`
`March 13, 2015
`
` Markman - the parties shall meet and confer to discuss and
`analyze the proposed construction of the claim terms, if the
`parties have a claim-term dispute.
`
`March 27, 2015
`
` Markman - jointly file a Joint Disputed Claim Terms Chart
`pursuant to Local Patent Rule 11.
`
`April 6, 2015
`
` Markman – Plaintiffs file opening claim construction brief,
`Defendants file opening claim construction brief and
`indefiniteness brief.
`
` Markman – Plaintiffs and Defendants file responsive claim
`construction brief and Plaintiffs file responsive
`indefiniteness brief.
`
`May 6, 2015
`
`June 8, 2015
`
` Markman – Defendants file reply indefiniteness brief.
`
`June 15, 2015
`
` Markman – Claim Construction Hearing to preferably occur
`no later than:
`
`August 31, 2015
`
`Plaintiffs’ position:
`Markman issues, if any, should be addressed after expert
`discovery. An indefiniteness defense is not part of a
`Markman hearing.
`
`Counsel for Plaintiff and Counsel for Defendants to meet and
`confer separately to discuss settlement.
`
`October 19, 2015
`
`10
`
`
`
`Case 1:14-cv-02758-PAC Document 24 Filed 10/03/14 Page 11 of 16
`
`Expert Discovery:
`Defendants’ proposal:
`All expert discovery, including depositions, to be completed no
`later than:
`
`March 11, 2016
`
` Expert Discovery – opening expert reports due:
`
`December 15, 2015
`
` Expert Discovery – responsive expert reports due:
`
`January 29, 2016
`
` Expert Discovery – reply expert reports due:
`
`February 15, 2016
`
`Plaintiffs’ position:
`Expert discovery should take place before Markman proceedings
`(if any).
`
`Deadline to file letter requesting permission to file summary
`judgment motions.
`
`March 11, 2016
`
`Parties to meet to confer on schedule for expert disclosures no
`later than:
`
`See ¶7 and above for
`proposed schedule.
`
`Final Pretrial Submission Date
`
`Date recommended by counsel for alternate dispute resolution:
`
`April 25, 2016
`
`See ¶11(c), but in no
`event no later than
`March 11, 2016
`
`Hearing on summary judgment motions (if any)
`
`TBD
`
`Defendants’ Proposal:
`Trial Begins:
`
`Defendants anticipate
`being trial-ready by
`August 2016
`
`Plaintiffs’ Proposal:
`Trial date to be scheduled by the Court after Final Pretrial
`Submission Date
`
`11
`
`
`
`Case 1:14-cv-02758-PAC Document 24 Filed 10/03/14 Page 12 of 16
`
`s/David G. Conlin
`Anthony J. Viola
`Andre K. Cizmarik
`Jennifer L. Dereka
`Zachary W. Silverman
`EDWARDS WILDMAN PALMER LLP
`750 Lexington Avenue
`New York, NY 10022
`(212) 308-4411
`aviola@edwardswildman.com
`acizmarik@edwardswildman.com
`jdereka@edwardswildman.com
`zsilverman@edwardswildman.com
`
`David G. Conlin (admitted pro hac vice)
`Kathleen B. Carr (admitted pro hac vice
`Adam P. Samansky
`EDWARDS WILDMAN PALMER LLP
`111 Huntington Avenue
`Boston, MA 02199
`dconlin@edwardswildman.com
`kcarr@edwardswildman.com
`asamansky@edwardswildman.com
`
`Attorneys for Plaintiffs
`Kowa Company, Ltd.
`Kowa Pharmaceuticals America, Inc. and
`Nissan Chemical Industries, Ltd.
`
`s/
`Andrew J. Miller
`Constance S. Huttner
`BUDD LARNER, PC
`150 John F. Kennedy Parkway
`Short Hills, N J 07078-2703
`(973) 379-4800
`amiller@buddlarner.com
`chuttner@buddlarner.com
`
`Attorneys for Defendant,
`Amneal Pharmaceuticals, LLC
`
`s/Paul Ainsworth
`H. Keeto Sabharwal
`Chandrika Vira
`Paul Ainsworth
`STERNE, KESSLER, GOLDSTEIN &
`FOX, PLLC
`1100 New York Avenue
`Washington, D.C. 20005
`(202) 772-8511
`keetos@skgf.com
`cvira@skgf.com
`
`Attorneys for Defendants
`Aurobindo Pharma Ltd. and
`Aurobindo Pharma USA Inc.
`
`12
`
`
`
`Case 1:14-cv-02758-PAC Document 24 Filed 10/03/14 Page 13 of 16
`
`s/Deanne M. Mazzochi
`Jakob B. Halpern
`SAIBER LLC
`One Gateway Center, Suite 1000
`Newark, NJ 07102
`(973) 622-3333
`jbh@saiber.com
`
`Of Counsel
`
`William A. Rakoczy
`Deanne M. Mazzochi
`Amy D. Brody
`Luke T. Shannon
`RAKOCZY MOLINO MAZZOCHI
`SIWIK LLP
`6 West Hubbard Street, Suite 500
`Chicago, IL 60654
`(312) 222-6301
`wrakoczy@rmmslegal.com
`dmazzochi@rmmslegal.com
`abrody@rmmslegal.com
`lshannon@rmmslegal.com
`
`Attorneys for Defendants
`Mylan Pharmaceuticals Inc. and Mylan Inc.
`
`s/Katherine E. Rohlf
`Steven Gerber
`Gonzalez Saggio & Harlan LLP
`292 Madison Avenue, Floor 19
`New York, NY 10017
`(212) 380-9560
`Steven_Gerber@gshllp.com
`
`13
`
`
`
`Case 1:14-cv-02758-PAC Document 24 Filed 10/03/14 Page 14 of 16
`
`Don J. Mizerk
`John A. Sholar
`Katherine E. Rohlf
`Husch Blackwell LLP
`120 S. Riverside Plaza, Suite 2200
`Chicago, IL 60606
`(312) 655-1500
`Don.Mizerk@huschblackwell.com
`John.Sholar@huschblackwell.com
`Katherine.Rohlf@huschblackwell.com
`
`Attorneys for Defendant
`Orient Pharma Co., Ltd.
`
`s/
`Craig S. Kesch
`One Liberty Plaza
`New York, NY 10006-1404
`(212) 412-9500
`ckesch@fzwz.com
`
`and
`
`Chidambaram S. Iyer
`Michael Dzwonczyk
`Azy S. Kokabi
`SUGHRUE MION, PLLC
`2100 Pennsylvania Avenue, NW
`Washington, D.C. 20037
`(202) 293-7060
`ciyer@sughrue.com
`mdzwonczyk@sughrue.com
`akokabi@sughrue.com
`
`Attorneys for Defendant
`Sawai USA Inc. and Sawai Pharmaceutical
`Co., Ltd.
`
`14
`
`
`
`Case 1:14-cv-02758-PAC Document 24 Filed 10/03/14 Page 15 of 16
`
`s/Vincent P. Rao II
`Steven J. Moore
`Vincent P. Rao II
`Elizabeth W. Swedock
`KELLEY DRYE & WARREN LLP
`101 Park Avenue
`New York, NY 10178
`(212) 808-7800
`smoore@kelleydrye.com
`vrao@kelleydrye.com
`eswedock@kelleydrye.com
`
`Attorneys for Defendants
`Zydus Pharmaceuticals (USA) Inc. and
`Cadila Healthcare Limited
`
`15
`
`
`
`Case 1:14-cv-02758-PAC Document 24 Filed 10/03/14 Page 16 of 16
`
`TO BE COMPLETED BY THE COURT:
`
`15.
`
`The next conference is scheduled for: ____/____/ 20____ @ ____: ____ AM / PM in
`Courtroom 14-C.
`
`This ORDER may not be modified or the dates herein extended, except
`by further Order of this Court for good cause shown. Any application to modify or
`extend shall be made in a written application in accordance with paragraph 1(E) of
`the Court’s Individual Practices and shall be made no less than two (2) days prior to
`the expiration of the date sought to be extended.
`
`Dated: ____/____/20____
`New York, NY
`
`Paul A. Crotty
`United States District Judge
`
`________________________________
`
`16
`
`