`Sent:
`To:
`Cc:
`
`Subject:
`
`Krinsky, David <DKrinsky@wc.com>
`Monday, October 10, 2016 4:11 PM
`Lydigsen, Laura; Sarah E. Spires
`Grossman, Dov; Perlman, Adam; Gabric, Ralph; James, Joshua; Richardson, Bryan T.;
`237Neptune; 240Neptune
`Depositions in IPR2016-00237, IPR2016-00240, IPR2016-00318
`
`Counsel,
`
`Neptune and Sandoz have each requested the depositions of Dr. Bruce Chabner and Dr. Steven
`Zeisel. As previously agreed, we will make each of them available for one single-day deposition in
`IPR2016-00237 and -00240, and for a second single-day deposition in IPR2016-00318. Given that
`Dr. Chabner and Dr. Zeisel both have very limited availability over the coming weeks, and given each
`Petitioner’s attendance at the other’s prior depositions, I thought it would be most efficient to offer
`dates to both Petitioners simultaneously:
`
`
`- Dr. Chabner is available for deposition on November 10 and November 16. Both dates would
`be in Boston, MA.
`
`- Dr. Zeisel is available for deposition on November 22 and November 30. The deposition on
`November 22 will be in the Charlotte/Kannapolis, NC area. We are still working to confirm
`where Dr. Zeisel will be available on November 30, but it will be in one of
`Charlotte/Kannapolis, Raleigh/Durham/Chapel Hill, NC, or Washington, DC.
`
`
`Please let me know if these dates are acceptable, as well as which Petitioner will be taking which
`dates.
`
`Both Neptune and Sandoz have also requested the deposition of Dr. Clet Niyikiza. However, as Dr.
`Niyikiza did not submit affidavit testimony prepared for the proceeding in any of these IPRs, his cross
`examination is not routine discovery and we do not intend to make him available for deposition.
`
`Best,
`
`David M. Krinsky
`Williams & Connolly LLP
`725 Twelfth Street, N.W.
`Washington, DC 20005
`+1 202 434 5338 (voice)
`+1 202 480 8302 (fax)
`dkrinsky@wc.com
`
`
`
`This message and any attachments are intended only for the addressee and may contain information that is privileged and
`confidential. If you have received this message in error, please do not read, use, copy, distribute, or disclose the contents of the
`message and any attachments. Instead, please delete the message and any attachments and notify the sender immediately. Thank
`you.
`
`1
`
`Sandoz Inc. IPR2016-00318
`Sandoz v. Eli Lilly, Exhibit 1134-0001
`
`
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