SYNTHON B.V. and SYNTHON

IT IS HEREBY STIPULATED AND AGREED, by and between the parties, subject to the approval of the Court, that the time for Defendants to serve Dr. Jonathan Steed’s reply expert report is extended to September 8, 2023.

Jack B. Blumenfeld (No. 1014) Megan E. Dellinger (No. 5739) 1201 North Market Street P.O.

30673362.1 SO ORDERED this _________ day of ______________, 2023.

Pursuant to the Court’s Transcript Redaction Policy and consistent with Local Rule 7.2, Plaintiff and Counterclaim-Defendant OssiFi-Mab LLC (“OMAB” or “Plaintiff”) and Defendant and Counterclaim-Plaintiff Amgen Inc. (“Amgen” or “Defendant”) (collectively, the “Parties”) hereby jointly move the Court to impound the transcript of the discovery hearing held before Chief Magistrate Judge Donald Cabell on December 2, 2024 (the “Transcript”).

The Transcript of the hearing references materials designated by both Parties as “Confidential Information” pursuant to the Protective Order (Dkt. No. 64) entered in this case.

Many of the pleadings and exhibits related to the Motions to Compel discussed at the hearing have been designated “Confidential Information” pursuant to the Protective Order and/or reference materials that have been designated “Confidential Information” pursuant to the Protective Order, and were previously submitted to the Court under seal in accordance with Local Rule 7.2.

The Parties respectfully request that the Court impound the following portions of the Transcript of this hearing disclosing such Confidential Information to preclude access to those pages by the public: Pg.

Upon request, the Parties will provide via email a courtesy copy of the transcript to the court, with the Parties’ proposed redactions highlighted in accordance with the above.

Plaintiff OssiFi-Mab LLC (“OMAB” or “Plaintiff”) and Defendant Amgen Inc. (“Amgen” or “Defendant”) (collectively, the “Parties”) hereby jointly move the Court to modify the case schedule with respect to rebuttal and reply expert reports.

In support thereof, the Parties state: WHEREAS, on July 31, 2023, the Parties submitted a Joint Statement Pursuant to Federal Rules 16(b) and 26(f) and Local Rules 16.1 and 16.6 outlining the Parties’ proposed discovery plan and pretrial schedule (D.I.

The Court allowed those joint motions, thereby extending the deadline to submit the ESI Protocol and Protective Order to October 6, 2023 (D.I.

Nos. 57, 59, and 61); WHEREAS, on September 12, 2024, the Parties jointly moved the Court to extend the deadline for fact discovery to provide additional time to complete fact depositions and exchanges of written discovery responses (D.I.

Modification to the rebuttal and reply expert report deadlines can be accommodated within the current case schedule without impact to the remainder of the schedule; WHEREAS, good cause exists for an extension of rebuttal and reply expert report deadlines.

May 16, 2011 In May 2005, Judge F. Dennis Saylor (and then Magistrate Judge Charles B. Swartwood), sitting in the Central Division (Worcester) of this Court, adopted a standing order “strongly encourag[ing] the participation of relatively inexperienced attorneys in all court proceedings.” As the Court explained at the time, the standing order was prompted by the recognition that the “[c]ourtroom opportunities for relatively inexperienced attorneys, particularly those who practice at larger firms, have declined precipitously across the nation in recent years.” This standing order remains in place in the Central Division for appearances before Judge Saylor and Magistrate Judge Timothy S. Hillman and anecdotal information indicates that the order has had the desired effect of having more well prepared junior attorneys attend status conferences, argue motions to the Court, and, under appropriate supervision, examine witnesses at trial.

Among its recommendations to the judiciary, the Task Force called upon “judges presiding over pre-trial conferences and related matters to identify and encourage opportunities for a junior attorney to participate in the examination of witnesses or other significant trial work.” To take up this call and attempt, in some small measure, to remedy the dearth of courtroom opportunities for newer attorneys, the undersigned judge issues this standing order, substantially similar in purpose and intent to the order previously adopted by the Central Division.

Accordingly, the undersigned judge, as a matter of policy, strongly encourages the participation of relatively inexperienced attorneys in all court proceedings including but not limited to initial scheduling conferences, status conferences, hearings on discovery motions and dispositive motions, and examination of witnesses at trial.

This includes relatively inexperienced attorneys with regard to knowledge of the case, overall preparedness, candor to the court and any other matter as to which experience is largely irrelevant.

If it is to have the desired effect of countering the trend of declining courtroom opportunities for relatively inexperienced attorneys, it is their more experienced, supervising colleagues who must effectuate the policy articulated in this standing order.

IT IS HEREBY STIPULATED AND AGREEDBYTHE PARTIES,subject to the approval of the Court, that the following deadlines are extended as set forth below:

Case Event Rebuttal Expert Reports Reply Expert Reports Close of Expert Discovery

Current Deadline June 19, 2023 July 28, 2023 September19, 2023 Noother deadlinesare altered by thisstipulation.

901 New York Avenue, N.W., Suite 900E Washington, DC 20001 SO ORDEREDthis 7 day of _June 2023.

The Honorable Colm F. cmaly Chief United States District Judge

Defendant Amgen Inc. (“Amgen”) respectfully requests leave of the Court to file its Sur- reply Memorandum of Law in Opposition to Plaintiff Ossifi-Mab LLC’s (“OMAB”) Motion to Compel Production of Documents (“Sur-reply”), pursuant to Local Rule 7.1(b)(3).

OMAB filed its Motion to Compel Production of Documents and accompanying Brief on October 10, 2024.

125-1 at 2–3 (arguing, for the first time in reply, that any license agreement is relevant here if it relates “to drug therapies that aim to target or inhibit a specific mechanism in the body,” regardless of the drug, the disease, or the treatment to which the license relates).

Amgen thus respectfully requests leave to file the attached, short sur-reply so it is afforded a fair opportunity to respond OMAB’s expansion of the record.

1 Amgen filed its own motion to compel today regarding OMAB’s refusal to produce certain documents concerning its small-molecule development program.

Pursuant to Local Rule 7.2, Defendant and Counterclaim-Plaintiff Amgen Inc. (“Amgen” or “Defendant”) hereby moves the Court to impound its Sur-reply Memorandum in Support of its Opposition to the Motion to Compel Production of Documents (“Sur-reply Memorandum”), to be filed on November 15, 2024, and to permit Defendant Amgen to file such document under seal.

These materials include, without limitation, (a) documents produced in this action that have been designated “Confidential Information” pursuant to the parties’ Protective Order, and (b) confidential discovery-related communications between the parties quoting or referencing Defendant’s confidentially designated document discovery.

These materials reference or include information that is Defendant’s confidential business information or trade secrets that may be of value to a potential competitor or, if made public, would harm their competitive position.

Defendant will serve on Plaintiff unredacted copies of the Sur-reply Memorandum and accompanying papers.

In addition, a redacted version of the Sur-reply Memorandum and accompanying papers will be filed with the Court as soon as practicable upon allowance of this motion.

Pursuant to Local Rule 7.2, Defendant and Counterclaim-Plaintiff Amgen Inc. (“Amgen” or “Defendant”) hereby moves the Court to impound its Memorandum in Support of its Motion to Compel Production of Documents (“Motion to Compel”), to be filed on November 15, 2024, and accompanying exhibits to the Declaration of A. Barel in support of the Motion to Compel (“Barel Declaration”), and to permit Defendant Amgen to file such documents under seal.

Exhibits to the Barel Declaration to be filed in support of the Motion to Compel have been designated “Confidential Information” pursuant to the parties’ Protective Order and/or reference materials that have been designated “Confidential Information” pursuant to the parties’ Protective Order.

These materials include, without limitation, (a) documents produced in this action that have been designated “Confidential Information” pursuant to the parties’ Protective Order, and (b) confidential discovery-related communications between the parties quoting or referencing Defendant’s confidentially designated document discovery.

Defendant will serve on Plaintiff unredacted copies of the Motion to Compel and accompanying papers.

Defendant submits that filing of unredacted copies of exhibits designated “Confidential Information” is not possible.

Defendant Amgen Inc. (“Defendant” or “Amgen”) respectfully requests the Court enter an

order compelling Plaintiff OssiFi-Mab LLC (“OMAB” or “Plaintiff”) to produce discovery regarding the mechanism of action, including binding epitope, of OMAB’s small-molecule drug candidate that OMAB contends competes with Evenity within fourteen days of the Court entering such an order.

Amgen respectfully requests to be heard at oral argument on this Motion on December 2, 2024, when the Court will be holding oral argument on OMAB’s motion to compel (D.I.

Pursuant to Local Rule 7.1, I hereby certify that counsel for Amgen has conferred with

OMAB’s counsel in a good faith effort to resolve or narrow the issues presented in this motion on October 11, 2024, and November 8, 2024, and in additional correspondence between the parties, and was unable to resolve the disputes at issue in the present motion.

requests leave of the Court to file its Reply Memorandum of Law in Support of Plaintiff Ossifi- Mab LLC’s Motion to Compel Production of Documents (“Reply”).

OMAB believes that good cause exists to file its Reply because a reply memorandum will assist the Court in ruling on Plaintiff’s Motion to Compel, in particular, by addressing arguments made by Amgen in its opposition related to the documents OMAB seeks.

Specifically, Amgen in its Memorandum of Law in Opposition to Plaintiff Ossifi-Mab LLC’s Motion to Compel Production of Documents (ECF No. 122) (“Opposition”) provides new information and arguments concerning the third-party licenses that are the subject of OMAB’s Motion to Compel that were not previously addressed in correspondence between the parties or at the parties’ meet and confer prior to the filing of OMAB’s motion, as well as additional information concerning the content of the redactions that OMAB requests the Court to remove.

OMAB does not agree that the sharing of the reply brief is necessary here and therefore understands that Amgen opposes its motion for leave.

OMAB therefore respectfully requests that this Court grant this Motion for Leave to File a Reply Memorandum.

Pursuant to Local Rule 7.2, Defendant and Counterclaim-Plaintiff Amgen Inc. (“Amgen” or “Defendant”) hereby moves the Court to impound its Memorandum in Support of its Opposition to the Motion to Compel Production of Documents (the “Opposition”), to be filed on October 24, 2024, and accompanying exhibits to the Declaration of M. Milea in support of the Opposition (“Milea Declaration”), and to permit Defendant Amgen to file such documents under seal.

Exhibits to the Milea Declaration to be filed in support of the Opposition have been designated “Confidential Information” pursuant to the parties’ Protective Order and/or reference materials that have been designated “Confidential Information” pursuant to the parties’ Protective Order.

These materials include, without limitation, (a) documents produced in this action that have been designated “Confidential Information” pursuant to the parties’ Protective Order, and (b) confidential discovery-related communications between the parties quoting or referencing Defendant’s confidentially designated document discovery.

Defendant will serve on Plaintiff unredacted copies of its Memorandum and accompanying papers.

In addition, a redacted version of the Memorandum and accompanying papers will be filed with the Court as soon as practicable upon allowance of this motion.

Defendants Biocon Biologics Inc. and Mylan Pharmaceuticals Inc. (collectively, the “Biocon Defendants”), through their undersigned counsel, move to join the recent Motion for Status Conference filed by Samsung, Formycon, Celltrion and Amgen (Dkt. No. 334).

The Biocon Defendants agree that Regeneron’s proposed delays unnecessarily prolong the adjudication of the parties’ disputes, and that expedient resolution of outstanding issues and scheduling disputes is appropriate at this time.

The Biocon Defendants thus respectfully join in the Motion for Status Conference, in order to discuss scheduling and resolution of outstanding issues in the Biocon Defendants’ litigation, and respectfully request that the Biocon Defendants are included should the Court deem a status conference appropriate at this time.

Date: September 18, 2024