`Filed: August 25, 2015
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________
`
`AMNEAL PHARMACEUTICALS LLC and PAR PHARMACEUTICAL, INC.
`
`Petitioners,
`
`v.
`
`JAZZ PHARMACEUTICALS, INC.
`
`Patent Owner
`
`________________
`
`Case IPR2015-00547
`
`Patent 7,756,107
`________________
`
`EXHIBIT 2039
`
`PROPOSED DISCOVERY REQUESTS BY PATENT OWNER
`
`
`
`
`
`
`
`
`
`JAZZ EXHIBIT 2039
`Amneal Pharms. et al. (Petitioners) v. Jazz Pharms., Inc. (Patent Owner)
`Case IPR2015-00547
`
`Page 1 of 3
`
`
`
`
`
`Patent Owner Jazz Pharmaceuticals, Inc. (“Jazz”) requests that Petitioners
`
`Amneal Pharmaceuticals LLC and Par Pharmaceutical, Inc. (together
`
`“Petitioners”) respond and produce the following documents and things.
`
`INSTRUCTIONS
`
`1.
`
`In responding to and producing documents and things responsive to
`
`these requests, the responding party shall comply with the instructions in the Patent
`
`Trial Practice Guide.
`
`2.
`
`A responding party shall timely amend its response upon learning that
`
`its response is incomplete or if additional responsive information is found.
`
`3.
`
`All responsive documents must be produced as they are kept in the
`
`usual course of business.
`
`4.
`
`A party is not required to produce documents or information subject
`
`to a claim of privilege, including attorney work product. A party withholding
`
`responsive documents or information on the basis of privilege shall provide a
`
`privilege log identifying the responsive documents being withheld.
`
`5.
`
`The production of responsive documents or information shall not
`
`constitute an express or implied waiver of any privilege held by the producing
`
`party.
`
`
`
`
`
`
`
`Page 2 of 3
`
`
`
`
`
`
`
`DEFINITIONS
`
`1.
`
`The term “Par Entities” means Par Pharmaceutical, Inc., Par
`
`Pharmaceutical Companies, Inc., Sky Growth Intermediate Holdings I, Inc., Sky
`
`Growth Intermediate Holdings II, Inc., and/or Par Pharmaceutical Holdings, Inc.
`
`and includes any employees, agents, counsel, representatives, or others authorized
`
`to act on behalf of any the Par Entities.
`
`2.
`
`The term “billing records” means invoices and engagement letters.
`
`REQUESTS FOR PRODUCTION
`
`Request for Production No. 1
`
`Billing records submitted from Arent Fox LLP, Sterne Kessler, Goldstein &
`
`Fox P.L.L.C., Maddox Edwards PLLC, or Robert J. Valuck, Ph.D. to any of the
`
`Par Entities to the extent they relate to IPR2015-00545, -546, -547, -548, -551,
`
`and/or -554.
`
`Request for Production No. 2
`
`Employment agreements between David Silverstein and any of the Par
`
`Entities and employment agreements between Lawrence Brown and any of the Par
`
`Entities.
`
`
`
`
`
`
`
`
`
`Page 3 of 3