`Filed: August 25, 2015
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`________________
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`AMNEAL PHARMACEUTICALS LLC and PAR PHARMACEUTICAL, INC.
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`Petitioners,
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`v.
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`JAZZ PHARMACEUTICALS, INC.
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`Patent Owner
`
`________________
`
`Case IPR2015-00554
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`Patent 7,668,730
`________________
`
`EXHIBIT 2039
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`PROPOSED DISCOVERY REQUESTS BY PATENT OWNER
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`
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`JAZZ EXHIBIT 2039
`Amneal Pharms. et al. (Petitioners) v. Jazz Pharms., Inc. (Patent Owner)
`Case IPR2015-00554
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`Page 1 of 3
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`
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`Patent Owner Jazz Pharmaceuticals, Inc. (“Jazz”) requests that Petitioners
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`Amneal Pharmaceuticals LLC and Par Pharmaceutical, Inc. (together
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`“Petitioners”) respond and produce the following documents and things.
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`INSTRUCTIONS
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`1.
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`In responding to and producing documents and things responsive to
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`these requests, the responding party shall comply with the instructions in the Patent
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`Trial Practice Guide.
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`2.
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`A responding party shall timely amend its response upon learning that
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`its response is incomplete or if additional responsive information is found.
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`3.
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`All responsive documents must be produced as they are kept in the
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`usual course of business.
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`4.
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`A party is not required to produce documents or information subject
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`to a claim of privilege, including attorney work product. A party withholding
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`responsive documents or information on the basis of privilege shall provide a
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`privilege log identifying the responsive documents being withheld.
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`5.
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`The production of responsive documents or information shall not
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`constitute an express or implied waiver of any privilege held by the producing
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`party.
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`Page 2 of 3
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`DEFINITIONS
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`1.
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`The term “Par Entities” means Par Pharmaceutical, Inc., Par
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`Pharmaceutical Companies, Inc., Sky Growth Intermediate Holdings I, Inc., Sky
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`Growth Intermediate Holdings II, Inc., and/or Par Pharmaceutical Holdings, Inc.
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`and includes any employees, agents, counsel, representatives, or others authorized
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`to act on behalf of any the Par Entities.
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`2.
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`The term “billing records” means invoices and engagement letters.
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`REQUESTS FOR PRODUCTION
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`Request for Production No. 1
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`Billing records submitted from Arent Fox LLP, Sterne Kessler, Goldstein &
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`Fox P.L.L.C., Maddox Edwards PLLC, or Robert J. Valuck, Ph.D. to any of the
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`Par Entities to the extent they relate to IPR2015-00545, -546, -547, -548, -551,
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`and/or -554.
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`Request for Production No. 2
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`Employment agreements between David Silverstein and any of the Par
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`Entities and employment agreements between Lawrence Brown and any of the Par
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`Entities.
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`Page 3 of 3
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