throbber
From:
`Sent:
`To:
`Cc:
`
`Subject:
`
`Frese, Bradford C. <Bradford.Frese@arentfox.com>
`Monday, May 02, 2016 2:35 PM
`Frank Calvosa
`Berman, Richard; Carlan, Janine; Matt Ruedy; Steve Maddox; Nick Cerrito; Eric Stops;
`Evangeline Shih; Gabriel Brier; Lyndsey Przybylski; John V Biernacki; David Cochran
`RE: IPR2015-01903
`
`Frank,
`
`Your proposal is acceptable to Petitioners. We do, however, reserve the right to depose any new individuals making
`declarations that Patent Owner submits with their response.
`
`Best regards,
`Bradford
`
`Bradford C. Frese
`Associate
`
`Arent Fox LLP | Attorneys at Law
`1717 K Street, NW
`Washington, DC 20006-5344
`202.857.6496 DIRECT | 202.857.6395 FAX
`bradford.frese@arentfox.com | www.arentfox.com
`
`
`
`From: Frank Calvosa [mailto:FrankCalvosa@quinnemanuel.com]
`Sent: Monday, May 02, 2016 10:46 AM
`To: Frese, Bradford C. <Bradford.Frese@arentfox.com>
`Cc: Berman, Richard <Richard.Berman@arentfox.com>; Carlan, Janine <Janine.Carlan@arentfox.com>; Matt Ruedy
`<MRuedy@meiplaw.com>; Steve Maddox <smaddox@meiplaw.com>; Nick Cerrito <NickCerrito@quinnemanuel.com>;
`Eric Stops <EricStops@quinnemanuel.com>; Evangeline Shih <EvangelineShih@quinnemanuel.com>; Gabriel Brier
`<GabrielBrier@quinnemanuel.com>; Lyndsey Przybylski <lyndseyprzybylski@quinnemanuel.com>; John V Biernacki
`<jvbiernacki@JonesDay.com>; David Cochran <dcochran@JonesDay.com>
`Subject: Re: IPR2015-01903
`
`Bradford,
`
`Please provide a response by 3 pm today.
`
`Thanks,
`
`Frank
`
`On Apr 27, 2016, at 11:04 PM, Frese, Bradford C. <Bradford.Frese@arentfox.com> wrote:
`
`Frank:
`
`
`We are considering Patent Owner’s offer and will get back to you shortly.
`
`
`Best regards,
`
`1
`
`JAZZ EXHIBIT 2009
`Amneal Pharms. et al. (Petitioners) v. Jazz Pharms., Inc. (Patent Owner)
`Case IPR2015-01903
`
`

`
`Bradford
`
`
`Bradford C. Frese
`Associate
`
`
`Arent Fox LLP | Attorneys at Law
`1717 K Street, NW
`Washington, DC 20006-5344
`202.857.6496 DIRECT | 202.857.6395 FAX
`bradford.frese@arentfox.com | www.arentfox.com
`
`
`
`From: Frank Calvosa [mailto:FrankCalvosa@quinnemanuel.com]
`Sent: Wednesday, April 27, 2016 5:52 PM
`To: Frese, Bradford C. <Bradford.Frese@arentfox.com>; Berman, Richard
`<Richard.Berman@arentfox.com>; Carlan, Janine <Janine.Carlan@arentfox.com>; Matt Ruedy
`<MRuedy@meiplaw.com>; Steve Maddox <smaddox@meiplaw.com>
`Cc: Nick Cerrito <NickCerrito@quinnemanuel.com>; Eric Stops <EricStops@quinnemanuel.com>;
`Evangeline Shih <EvangelineShih@quinnemanuel.com>; Gabriel Brier
`<GabrielBrier@quinnemanuel.com>; Lyndsey Przybylski <lyndseyprzybylski@quinnemanuel.com>; John
`V Biernacki <jvbiernacki@JonesDay.com>; David Cochran <dcochran@JonesDay.com>
`Subject: Re: IPR2015-01903
`
`
`
`Counsel,
`
`
`
`
`
`Please let us know whether you agree to Jazz’s proposal in the email below. If not, please provide your
`availability for a call with the Board to further discuss this issue.
`
`
`
`
`
`Regards,
`
`
`
`Frank
`
`
`On Apr 20, 2016, at 4:57 PM, Frank Calvosa <FrankCalvosa@quinnemanuel.com> wrote:
`
`Counsel,
`
`
`The issues for the instituted claims in IPR2015-01903 (the “’963 IPR”) and IPR2015-
`00545, -546, -547, -548, -551, -554 (the “REMS IPRs”) are overlapping. In an effort to
`conserve the parties’ resources, please let us know whether Petitioners agree to Patent
`Owner using Dr. Valuck’s deposition testimony, from the REMS IPRs, in the ’963 IPR. In
`exchange, Patent Owner will agree to forego Dr. Valuck’s deposition in the ’963 IPR,
`related to his opening declaration. Patent Owner will also agree that Dr. DiPiro’s and Dr.
`Bergeron’s deposition testimony from the REMS IPRs can be used in the ’963 IPR, and
`that Patent Owner will rely only on Dr. DiPiro’s and Dr. Bergeron’s previously disclosed
`opinions, from the REMS IPRs, in the ’963 IPR.
`
`2
`
`Page 2 of 3
`
`

`
`
`
`Please let us know your response by Tuesday, April 26.
`
`
`Regards,
`
`
`Frank Calvosa
`
`Associate
`Quinn Emanuel Urquhart & Sullivan, LLP
`
`51 Madison Avenue, 22nd Floor
`New York, NY 10010
`212-849-7569 Direct
`212-849-7000 Main Office Number
`212-849-7100 FAX
`frankcalvosa@quinnemanuel.com
`www.quinnemanuel.com
`
`NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the
`recipient(s) named above. This message may be an attorney-client communication and/or work product and as such is
`privileged and confidential. If the reader of this message is not the intended recipient or agent responsible for
`delivering it to the intended recipient, you are hereby notified that you have received this document in error and that
`any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this
`communication in error, please notify us immediately by e-mail, and delete the original message.
`
`
`
`CONFIDENTIALITY NOTICE: This e-mail and any attachments are for the exclusive and confidential use of the intended recipient. If you
`received this in error, please do not read, distribute, or take action in reliance upon this message. Instead, please notify us immediately by
`return e-mail and promptly delete this message and its attachments from your computer system. We do not waive attorney-client or work
`product privilege by the transmission of this message.
`
`
`
`CONFIDENTIALITY NOTICE: This e-mail and any attachments are for the exclusive and confidential use of the intended recipient. If you received this in error,
`please do not read, distribute, or take action in reliance upon this message. Instead, please notify us immediately by return e-mail and promptly delete this
`message and its attachments from your computer system. We do not waive attorney-client or work product privilege by the transmission of this message.
`
`3
`
`Page 3 of 3

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