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TAKEDA PHARMACEUTICALS, CO., LTD. v. SANDOZ, INC., 3:12-cv-0446 JCS. (2013)

Court: District Court, N.D. California Number: infdco20130711830 Visitors: 3
Filed: Jul. 09, 2013
Latest Update: Jul. 09, 2013
Summary: STIPULATION AND [PROPOSED] ORDER TO AMEND THE FURTHER CASE MANAGEMENT AND PRETRIAL ORDER JOSEPH C. SPERO, District Judge. Pursuant to this Court's Civil Standing Orders and Civil Local Rules 6-1, 6-2, 7-12, and 16-10(c), Plaintiffs Takeda Pharmaceutical Company Limited, Takeda Pharmaceuticals U.S.A., Inc., Takeda Pharmaceuticals LLC, and Takeda Pharmaceuticals America, Inc., (collectively, "Takeda"), and Defendant Sandoz Inc. ("Sandoz") (collectively, the "Parties") stipulate and agree a
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STIPULATION AND [PROPOSED] ORDER TO AMEND THE FURTHER CASE MANAGEMENT AND PRETRIAL ORDER

JOSEPH C. SPERO, District Judge.

Pursuant to this Court's Civil Standing Orders and Civil Local Rules 6-1, 6-2, 7-12, and 16-10(c), Plaintiffs Takeda Pharmaceutical Company Limited, Takeda Pharmaceuticals U.S.A., Inc., Takeda Pharmaceuticals LLC, and Takeda Pharmaceuticals America, Inc., (collectively, "Takeda"), and Defendant Sandoz Inc. ("Sandoz") (collectively, the "Parties") stipulate and agree as follows:

WHEREAS, on June 1, 2012, the Court held the initial case management conference in this case;

WHEREAS, on June 6, 2012 the Court entered its Case Management and Pretrial Order [Docket No. 50] ("June 2012 Order");

WHEREAS, on September 7, 2012, the Court held a further case management conference;

WHEREAS, on September 11, 2012 the Court modified the June 2012 Order in its Further Case Management and Pretrial Order [Docket No. 55] ("September 2012 Order");

WHEREAS, on December 14, 2012, the Court held a further case management conference;

WHEREAS, on December 19, 2012 the Court modified the September 2012 Order in its Further Case Management and Pretrial Order [Docket No. 63] ("December 2012 Order");

WHEREAS, on April 9, 2013, the Court modified the December 2012 Order in its Further Case Management and Pretrial Order [Docket No. 76] ("April 2013 Order");

WHEREAS, on June 19, 2013, the Court granted Plaintiffs' motion to amend their infringement contentions to assert infringement under the doctrine of equivalents [Docket No. 92];

WHEREAS, the Parties, in light of Plaintiffs' Amended Infringement Contentions, have conferred and agreed upon related adjustments to the Schedule set forth in the April 2013 Order; [REDACTED];

THEREFORE, the undersigned Parties submit this stipulated request and respectfully request the Court amend April 2013 Order as follows:

Event Current Date Proposed Change Fact Discovery Cut-Off Friday, 07/19/13 Friday, 10/11/2013 Initial Expert Reports on Issues where Friday, 08/30/13 Friday, 11/22/2013 party Bears Burden of Proof. Takeda will provide any report on secondary considerations at this time. Rebuttal Expert Reports Friday, 09/27/13 Friday, 12/20/2013 Expert Discovery Cut-Off Friday, 10/25/13 Friday, 1/17/2014 Last Day to File Dispositive Motions Friday, 11/15/13 Friday, 2/7/2014 Oppositions Due for Dispositive Motions Friday, 12/06/13 Friday, 2/28/2014 Replies Due for Dispositive Motions Filed Friday, 12/20/13 Friday, 3/14/2014 Motions Hearing Friday, 02/28/14 To be set at a future case 9:30 a.m. management conference Pretrial Conference To be set at a future case (no change) management conference Trial To be set at a future case (no change) management conference

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

Source:  Leagle

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