`Filed4131±7-PaWTöTZP1Ufl24
`-M-MP-—-Doc”mnt
`Case 2:16 cv-090
`
`Sâiber
`
`ATTORNtY5 AT LAW
`
`Arnold B. Calmann
`(973) 645-4828
`abc()saiber.com
`
`BY CM/ECF
`
`November 13, 2017
`
`The Honorable Mark Falk, U.S.M.J.
`United States District Court
`Martin Luther King Building & U.S. Courthouse
`50 Walnut Street
`Newark, NJ 07101
`
`Re:
`
`Abraxis Bioscience, LLC et aL v. Cipta Ltd.,
`Civil Action No. 2:16-cv-09074 (JMV) (MF)
`
`This firm, together with K&L Gates, represents Defendant Cipla Ltd. (“Cipla”) in
`
`the above matter. We write with the consent of Plaintiffs Abraxis Bioscience, LLC and
`
`Celgene Corporation (collectively “Plaintiffs”) to respectfully request the Court’s
`
`approval of a modest 7-day extension of time — from November 14, 2017 to November
`
`21, 2017— for the parties to submit the Joint Claim Construction and Prehearing
`
`Statement pursuant to L. Pat. R. 4.3 (ECF No. 4$). We would very much appreciate the
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`Court’s approval of the additional time, as the parties’ communications have indicated
`
`that claim construction might not be necessary. To that end, counsel have been
`
`communicating in a good-faith effort to resolve any claim construction disputes and
`
`believe that they may be able to come to an agreement that would moot the need for
`
`Markrnan proceedings.
`
`In the event that the parties are unable to reach agreement, the
`
`parties will jointly approach the Court with a proposed revised schedule for completing
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`Saiber IC. One Gateway Center, 10’ floor, Suite 1000. Newark, New Jersey. 07102-5311 Tel 9736223333. Fax 973.2862465. ww.saiber.com
`Newark . New York
`Flotham Park
`
`
`
`Case 2:16-cv-09074-JMV-MF Document 70 Filed 11/14/17 Page 2 of 2 PageID: 629
`lUed 11/13/17 Page 2 of 2 PagelD: 625
`Case 2:16-cv-09074-]MV-MP Document 68
`
`The Honorable Mark falk, U.S.M.J.
`November 13, 2017
`Page 2
`
`the Local Patent Rules exchanges, submitting the L. Pat. R. 4.3 Statement, and
`
`conducting Markman proceedings.
`
`If the requested extension is acceptable to the Court, we would respectfully
`
`request that the Court execute the below provision and have this letter filed with the
`
`Clerk of the Court.
`
`We thank the Court for its consideration and continued assistance in this matter.
`
`Arnold B. Calmann
`
`cc:
`
`Counsel of record (by CM/ECf)
`
`The above request for a 7-day extension of time, to
`November 21, 2017, for the parties to submit the Joint
`Claim Construction and Prehearing Statement pursuant
`to L. Pat. R. 4.3 in this matter is hereby granted
`day ovember, 2017.
`t7’
`this
`
`
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