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UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`NALOX-1 PHARMACEUTICALS, LLC,
`Petitioner,
`
`v.
`
`ADAPT PHARMA OPERATIONS LIMITED, AND
`OPIANT PHARMACEUTICALS, INC.,
`Patent Owner.
`__________________
`
`Case IPR2019-00688
`U.S. Patent 9,468,747
`__________________
`
`
`
`PATENT OWNER’S OBJECTIONS TO EVIDENCE SUBMITTED BY
`PETITIONER IN SUPPORT OF REPLY
`
`

`

`Case IPR2019-00688
`U.S. Patent 9,468,747
`
`
`
`Pursuant to 37 C.F.R. § 42.64, Patent Owners Adapt Pharma Operations
`
`Limited and Opiant Pharmaceuticals, Inc. submit the following objections to the
`
`exhibits submitted by Petitioner Nalox-1 Pharmaceuticals, LLC in support of its
`
`reply filed March 12, 2020.
`
`Exhibit 1201 is or purports to be a Supplemental Declaration of Maureen
`
`Donovan, Ph.D. Patent Owners object to Exhibit 1201 under FRE 401, 402, and
`
`403 as irrelevant. Patent Owners further object to Exhibit 1201 as not responsive
`
`to the arguments and evidence cited in the Patent Owner’s Response and/or an
`
`improper attempt to present new evidence that could have been presented earlier in
`
`violation of, e.g., 37 C.F.R. § 42.23(b), including for example in paragraphs 12–18,
`
`20, 22, 24–25, 28, and 30–31 (including their accompanying footnotes).
`
`Exhibit 1202 is or purports to be a Supplemental Declaration of Günter
`
`Hochhaus, Ph.D. Patent Owners object to Exhibit 1202 under FRE 401, 402, and
`
`403 as irrelevant. Patent Owners further object to Exhibit 1202 as not responsive
`
`to the arguments and evidence cited in the Patent Owner’s Response and/or an
`
`improper attempt to present new evidence that could have been presented earlier in
`
`violation of, e.g., 37 C.F.R. § 42.23(b), including for example in paragraphs 19–25,
`
`29–31, 34–40, and 42–44 (including their accompanying footnotes). In addition,
`
`Patent Owners object under FRE 401, 402, 403, 702 and 703 and 21 C.F.R.
`
`§ 42.65(a)–(b) for failure to disclose the underlying facts and data on which Dr.
`
`2
`
`

`

`Case IPR2019-00688
`U.S. Patent 9,468,747
`
`
`Hochhaus based his “simulations,” “model[s],” and/or “calcula[tions]” or to
`
`provide the required affidavit and information in support thereof, including for
`
`example in paragraphs 19, 31, 34–35, 49, 51, 53–54 (including their accompanying
`
`footnotes). Patent Owners further object under FRE 401, 402, 403, 701, 702, and
`
`703 because Dr. Hochhaus is not qualified to offer opinions about the clinical
`
`practice of administering naloxone to treat opioid overdose and does not have
`
`personal experience doing so, including for example in paragraphs 21–22, 27–28
`
`(including their accompanying footnotes).
`
`Patent Owners object to Exhibit 1203 under FRE 401, 402, 403, and 901 as
`
`irrelevant (including because it is not prior art) and not authenticated. Patent
`
`Owners further object to Exhibit 1203 as not responsive to the arguments and
`
`evidence cited in the Patent Owner’s Response and/or an improper attempt to
`
`present new evidence that could have been presented earlier in violation of, e.g., 37
`
`C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1204 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1204 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`attempt to present new evidence that could have been presented earlier in violation
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`3
`
`

`

`Case IPR2019-00688
`U.S. Patent 9,468,747
`
`
`
`Patent Owners object to Exhibit 1206 under FRE 401, 402, and 403 as
`
`irrelevant (including because it is not prior art). Patent Owners further object to
`
`Exhibit 1206 as not responsive to the arguments and evidence cited in the Patent
`
`Owner’s Response and/or an improper attempt to present new evidence that could
`
`have been presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1207 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1207 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`attempt to present new evidence that could have been presented earlier in violation
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1208 under FRE 106, 401, 402, 403, and
`
`901 as incomplete, irrelevant, and not authenticated. Patent Owners further object
`
`to Exhibit 1208 as not responsive to the arguments and evidence cited in the
`
`Patent Owner’s Response and/or an improper attempt to present new evidence that
`
`could have been presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1210 under FRE 106, 401, 402, 403, and
`
`901 as incomplete, irrelevant, and not authenticated. Patent Owners further object
`
`to Exhibit 1210 as not responsive to the arguments and evidence cited in the
`
`Patent Owner’s Response and/or an improper attempt to present new evidence that
`
`could have been presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`4
`
`

`

`Case IPR2019-00688
`U.S. Patent 9,468,747
`
`
`
`Patent Owners object to Exhibit 1211 under FRE 401, 402, 403, 801, 802,
`
`805, and 901 as irrelevant (including because it is not prior art), inadmissible
`
`hearsay, and not authenticated. Patent Owners further object to Exhibit 1211 as
`
`not responsive to the arguments and evidence cited in the Patent Owner’s
`
`Response and/or an improper attempt to present new evidence that could have been
`
`presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1213 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1213 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`attempt to present new evidence that could have been presented earlier in violation
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1214 under FRE 106, 401, 402, 403, and
`
`901 as incomplete, irrelevant, and not authenticated. Patent Owners further object
`
`to Exhibit 1214 as not responsive to the arguments and evidence cited in the
`
`Patent Owner’s Response and/or an improper attempt to present new evidence that
`
`could have been presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1215 under FRE 106, 401, 402, 403, and
`
`901 as incomplete, irrelevant, and not authenticated. Patent Owners further object
`
`to Exhibit 1215 as not responsive to the arguments and evidence cited in the
`
`5
`
`

`

`Case IPR2019-00688
`U.S. Patent 9,468,747
`
`
`Patent Owner’s Response and/or an improper attempt to present new evidence that
`
`could have been presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1216 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1216 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`attempt to present new evidence that could have been presented earlier in violation
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1217 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1217 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`attempt to present new evidence that could have been presented earlier in violation
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1218 under FRE 401, 402, and 403 as
`
`irrelevant (including because it is not prior art). Patent Owners further object to
`
`Exhibit 1218 as not responsive to the arguments and evidence cited in the Patent
`
`Owner’s Response and/or an improper attempt to present new evidence that could
`
`have been presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1219 under FRE 401, 402, 403, 801, 802,
`
`805, and 901 as irrelevant (including because it is not prior art), inadmissible
`
`hearsay, and not authenticated. Patent Owners further object to Exhibit 1219 as
`
`6
`
`

`

`Case IPR2019-00688
`U.S. Patent 9,468,747
`
`
`not responsive to the arguments and evidence cited in the Patent Owner’s
`
`Response and/or an improper attempt to present new evidence that could have been
`
`presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1220 under FRE 401, 402, 403, 801, 802,
`
`805, and 901 as irrelevant (including because it is not prior art), inadmissible
`
`hearsay, and not authenticated. Patent Owners further object to Exhibit 1220 as
`
`not responsive to the arguments and evidence cited in the Patent Owner’s
`
`Response and/or an improper attempt to present new evidence that could have been
`
`presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1221 under FRE 106, 401, 402, 403, and
`
`901 as incomplete, irrelevant, and not authenticated. Patent Owners further object
`
`to Exhibit 1221 as not responsive to the arguments and evidence cited in the
`
`Patent Owner’s Response and/or an improper attempt to present new evidence that
`
`could have been presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1222 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1222 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`attempt to present new evidence that could have been presented earlier in violation
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`7
`
`

`

`Case IPR2019-00688
`U.S. Patent 9,468,747
`
`
`
`Patent Owners object to Exhibit 1223 under FRE 401, 402, and 403 as
`
`irrelevant (including because it is not prior art). Patent Owners further object to
`
`Exhibit 1223 as not responsive to the arguments and evidence cited in the Patent
`
`Owner’s Response and/or an improper attempt to present new evidence that could
`
`have been presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1224 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1224 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`attempt to present new evidence that could have been presented earlier in violation
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1225 under FRE 401, 402, and 403 as
`
`irrelevant (including because it is not prior art). Patent Owners further object to
`
`Exhibit 1225 as not responsive to the arguments and evidence cited in the Patent
`
`Owner’s Response and/or an improper attempt to present new evidence that could
`
`have been presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1226 under FRE 401, 402, and 403 as
`
`irrelevant (including because it is not prior art). Patent Owners further object to
`
`Exhibit 1226 as not responsive to the arguments and evidence cited in the Patent
`
`Owner’s Response and/or an improper attempt to present new evidence that could
`
`have been presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`8
`
`

`

`Case IPR2019-00688
`U.S. Patent 9,468,747
`
`
`
`Patent Owners object to Exhibit 1227 under FRE 106, 401, 402, 403, 801,
`
`802, 805, and 901 as irrelevant (including because it is not prior art), inadmissible
`
`hearsay, not authenticated, and an improper compilation of multiple documents.
`
`Patent Owners further object to Exhibit 1227 as not responsive to the arguments
`
`and evidence cited in the Patent Owner’s Response and/or an improper attempt to
`
`present new evidence that could have been presented earlier in violation of, e.g., 37
`
`C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1228 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1228 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`attempt to present new evidence that could have been presented earlier in violation
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1229 under FRE 401, 402, and 403 as
`
`irrelevant (including because it is not prior art). Patent Owners further object to
`
`Exhibit 1229 as not responsive to the arguments and evidence cited in the Patent
`
`Owner’s Response and/or an improper attempt to present new evidence that could
`
`have been presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1230 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1230 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`9
`
`

`

`
`attempt to present new evidence that could have been presented earlier in violation
`
`Case IPR2019-00688
`U.S. Patent 9,468,747
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1231 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1231 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`attempt to present new evidence that could have been presented earlier in violation
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1233 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1233 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`attempt to present new evidence that could have been presented earlier in violation
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1234 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1234 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`attempt to present new evidence that could have been presented earlier in violation
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1235 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1235 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`10
`
`

`

`
`attempt to present new evidence that could have been presented earlier in violation
`
`Case IPR2019-00688
`U.S. Patent 9,468,747
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1236 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1236 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`attempt to present new evidence that could have been presented earlier in violation
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1237 under FRE 106, 401, 402, 403, and
`
`901 as incomplete, irrelevant, and not authenticated. Patent Owners further object
`
`to Exhibit 1237 as not responsive to the arguments and evidence cited in the
`
`Patent Owner’s Response and/or an improper attempt to present new evidence that
`
`could have been presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1238 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1238 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`attempt to present new evidence that could have been presented earlier in violation
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1239 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1239 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`11
`
`

`

`
`attempt to present new evidence that could have been presented earlier in violation
`
`Case IPR2019-00688
`U.S. Patent 9,468,747
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1240 under FRE 401, 402, 403, and 37
`
`C.F.R. § 42.6(c) as irrelevant and because it was not filed with a document citing it
`
`and therefore lacks probative value. Patent Owners further object to Exhibit 1240
`
`as not responsive to the arguments and evidence cited in the Patent Owner’s
`
`Response and/or an improper attempt to present new evidence that could have been
`
`presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1241 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1241 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`attempt to present new evidence that could have been presented earlier in violation
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1242 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1242 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`attempt to present new evidence that could have been presented earlier in violation
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1243 under FRE 401, 402, 403, 801, 802,
`
`805, and 901 as irrelevant (including because it is not prior art), inadmissible
`
`12
`
`

`

`Case IPR2019-00688
`U.S. Patent 9,468,747
`
`
`hearsay, and not authenticated. Patent Owners further object to Exhibit 1243 as
`
`not responsive to the arguments and evidence cited in the Patent Owner’s
`
`Response and/or an improper attempt to present new evidence that could have been
`
`presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1244 under FRE 401, 402, 403, 801, 802,
`
`805, and 901 as irrelevant (including because it is not prior art), inadmissible
`
`hearsay, and not authenticated. Patent Owners further object to Exhibit 1244 as
`
`not responsive to the arguments and evidence cited in the Patent Owner’s
`
`Response and/or an improper attempt to present new evidence that could have been
`
`presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1245 under FRE 401, 402, 403, 801, 802,
`
`805, and 901 as irrelevant (including because it is not prior art), inadmissible
`
`hearsay, and not authenticated. Patent Owners further object to Exhibit 1245 as
`
`not responsive to the arguments and evidence cited in the Patent Owner’s
`
`Response and/or an improper attempt to present new evidence that could have been
`
`presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1246 under FRE 401, 402, 403, 801, 802,
`
`805, and 901 as irrelevant (including because it is not prior art), inadmissible
`
`hearsay, and not authenticated. Patent Owners further object to Exhibit 1246 as
`
`not responsive to the arguments and evidence cited in the Patent Owner’s
`
`13
`
`

`

`Case IPR2019-00688
`U.S. Patent 9,468,747
`
`
`Response and/or an improper attempt to present new evidence that could have been
`
`presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1247 under FRE 401, 402, 403, 801, 802,
`
`805, and 901 as irrelevant (including because it is not prior art), inadmissible
`
`hearsay, and not authenticated. Patent Owners further object to Exhibit 1247 as
`
`not responsive to the arguments and evidence cited in the Patent Owner’s
`
`Response and/or an improper attempt to present new evidence that could have been
`
`presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1248 under FRE 106, 401, 402, and 403 as
`
`incomplete and irrelevant. Exhibit 1248 is incomplete because Petitioner did not
`
`submit to the Board a complete set of all exhibits used at Dr. Jones’s deposition.
`
`Patent Owners object to Exhibit 1249 under FRE 106, 401, 402, 403, and
`
`901 as incomplete, irrelevant, and not authenticated. Patent Owners further object
`
`to Exhibit 1249 as not responsive to the arguments and evidence cited in the
`
`Patent Owner’s Response and/or an improper attempt to present new evidence that
`
`could have been presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1250 under FRE 401, 402, 403, 801, 802,
`
`805, and 901 as irrelevant (including because it is not prior art), inadmissible
`
`hearsay, and not authenticated. Patent Owners further object to Exhibit 1250 as
`
`not responsive to the arguments and evidence cited in the Patent Owner’s
`
`14
`
`

`

`Case IPR2019-00688
`U.S. Patent 9,468,747
`
`
`Response and/or an improper attempt to present new evidence that could have been
`
`presented earlier in violation of, e.g., 37 C.F.R. § 42.23(b).
`
`Patent Owners object to Exhibit 1251 under FRE 401, 402, and 403 as
`
`irrelevant. Patent Owners further object to Exhibit 1251 as not responsive to the
`
`arguments and evidence cited in the Patent Owner’s Response and/or an improper
`
`attempt to present new evidence that could have been presented earlier in violation
`
`of, e.g., 37 C.F.R. § 42.23(b).
`
`
`Date: March 19, 2020
`
`
`
`Respectfully submitted,
`
`/Jessamyn S. Berniker/
`
`Jessamyn S. Berniker (Reg. No. 72,328)
`Ana C. Reyes (Admitted Pro Hac Vice)
`David M. Krinsky (Reg. No. 72,339)
`Anthony H. Sheh (Reg. No. 70,576)
`WILLIAMS & CONNOLLY LLP
`725 Twelfth Street, N.W.
`Washington, DC 20005
`T: (202) 434-5000
`F: (202) 434-5029
`jberniker@wc.com
`areyes@wc.com
`dkrinsky@wc.com
`asheh@wc.com
`
`Counsel for Patent Owner
`Adapt Pharma Operations Limited
`
`
`/Jessica Tyrus Mackay/
`
`Jessica Tyrus Mackay (Reg. No. 64,742)
`Ann K. Kotze (Reg. No. 76,570)
`
`15
`
`

`

`
`
`Case IPR2019-00688
`U.S. Patent 9,468,747
`
`GREEN, GRIFFITH & BORG-BREEN, LLP
`676 North Michigan Avenue, Suite 3900
`Chicago, IL 60611
`(313) 883-8000
`jmackay@greengriffith.com
`akotze@greengriffith.com
`
`Counsel for Patent Owner
`Opiant Pharmaceuticals, Inc.
`
`
`
`
`
`
`16
`
`

`

`Case IPR2019-00688
`U.S. Patent 9,468,747
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certifies that a true
`
`and correct copy of the foregoing was served on March 19, 2020, by delivering a
`
`copy via electronic mail on the following attorneys of record:
`
`Yelee Y. Kim
`Janine A. Carlan
`Richard Berman
`Bradford Frese
`Christopher Yaen
`ARENT FOX LLP
`1717 K Street NW
`Washington, DC 20036
`Yelee.Kim@arentfox.com
`Janine.Carlan@arentfox.com
`Richard.Berman@arentfox.com
`Bradford.Frese@arentfox.com
`Christopher.Yaen@arentfox.com
`
`/Jessamyn S. Berniker/
`
`Jessamyn S. Berniker (Reg. No. 72,328)
`
`
`
`
`
`
`
`
`
`
`
`17
`
`

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