`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`
`MYLAN PHARMACEUTICALS INC.,
`MSN LABORATORIES PRIVATE LTD.,
`and MSN PHARMACEUTICALS INC.,
`
`
`Petitioner,
`
`v.
`
`BAUSCH HEALTH IRELAND LIMITED,
`
`Patent Owner.
`
`__________________
`
`Case IPR2022-007221
`U.S. Patent No. 7,041,786
`__________________
`
`PATENT OWNER’S
`NOTICE OF DEPOSITION OF MICHAEL S. EPSTEIN, M.D.
`
`
`
`
`
`
`
`
`1 IPR2023-00016 has been joined with this proceeding.
`
`
`
`Case No. IPR2022-00722
`U.S. Patent No. 7,041,786
`
`Patent Owner Bausch Health Ireland Limited hereby provides notice that it
`
`will cross-examine Michael S. Epstein, M.D., a witness of Petitioner Mylan
`
`Pharmaceuticals Inc. The parties have agreed that the cross-examination will be
`
`conducted at Wilson Sonsini Goodrich & Rosati, 1700 K St. NW, Washington, DC
`
`20006 on April 11, 2023. The cross-examination will begin at 9:00 am Eastern.
`
`The cross-examination will be recorded by stenographic means by a court
`
`reporter licensed to administer oaths and may also be recorded using audio means.
`
`The individual signing below has the authority to execute this document on behalf
`
`of Patent Owner Bausch Health Ireland Limited.
`
`
`
`Date: March 31, 2023
`
`Respectfully submitted,
`
`
`
`
`/Justin J. Hasford/
`By:
`Justin J. Hasford, Reg. No. 62,180
`Lead Counsel
`Bryan C. Diner, Reg. No. 32,409
`Back-up Counsel
`Joshua L. Goldberg, Reg. No. 59,369
`Back-up Counsel
`Kassandra M. Officer Reg. No. 74,083
`Back-up Counsel
`Lauren J. Robinson Reg. No. 74,100
`Back-up Counsel
`Caitlin E. O’Connell, Reg. No. 73,934
`Back-up Counsel
`Kyu Yun Kim, Reg. No. 72,783
`Back-up Counsel
`
`FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, L.L.P.
`2
`
`
`
`
`Case No. IPR2022-00722
`U.S. Patent No. 7,041,786
`
`
`901 New York Ave. NW
`Washington, DC 20001-4413
`(202) 408-4000
`
`Counsel for the Patent Owner
`
`3
`
`
`
`
`Case No. IPR2022-00722
`U.S. Patent No. 7,041,786
`
`
`CERTIFICATE OF SERVICE
`
`
`
`The undersigned hereby certifies that a copy of the foregoing Patent Owner’s
`
`Notice of Deposition of Michael S. Epstein, M.D. served electronically via email
`
`on March 31, 2023, to counsel of record for the Petitioner at the following:
`
`Jad A. Mills
`Wilson Sonsini Goodrich & Rosati PC
`701 Fifth Avenue, Suite 5100
`Seattle, WA 98104-7036
`jmills@wsgr.com
`
`Richard Torczon
`Tasha M. Thomas
`Wilson Sonsini Goodrich & Rosati PC
`1700 K Street N.W., 5th Floor
`Washington, DC 20006
`rtorczon@wsgr.com
`tthomas@wsgr.com
`
`
`Dennis D. Gregory
`Wilson Sonsini Goodrich & Rosati PC
`900 South Capital of Texas Highway, Las Cimas IV, Fifth Floor
`Austin, TX 78746-5546
`dgregory@wsgr.com
`
`4863-5899-2145@mail.vault.netdocuments.com
`
`Andrew O. Larsen
`Merchant & Gould, P.C.
`500 Fifth Avenue, Suite 4100
`New York, NY 10110
`alarsen@merchantgould.com
`
`Melissa Hayworth
`Merchant & Gould, P.C.
`
`
`
`
`
`Case No. IPR2022-00722
`U.S. Patent No. 7,041,786
`
`
`1900 Duke, Street, Suite 600
`Alexandria, VA 22314
`mhayworth@merchantgould.com
`
`Christopher J. Sorenson
`Merchant & Gould, P.C.
`150 South Fifth Street, Suite 2200
`Minneapolis, MN 55402
`csorenson@merchantgould.com
`
`plecanatidemerchant@merchantgould.com
`
`
`
`Dated: March 31, 2023
`
`
`
`
`
`
`
`
`
`
`
`/Geneva Eaddy/
`Geneva Eaddy
`Case Manager
`FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER LLP
`
`
`
`
`
`
`
`
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