07/28/2014 16:55 FAX 19732866800 SAULEWING flJ 002/004 . 

SaulEwigg 

YJA FACSIMILE <609> 989·0451 

The Honorable Douglas E. Arpert, U.S.M.J. 

United States District Court 

Clarkson S. Fisher Building&. U.S. Courthouse 

402 East State Street 

Trenton, NJ 08608 

RECEIVED 

JUL 3 1 2014 

'-'' ··1!1. M VI! ·;.A.LSH CLERK 

July 28, 2014 

William C. 'Baton 

Phone: (973) 186-6722 

'Fax: (973) 286·6822 

Wbaton®saul, aom 

www.saul.com 

RECEIVED 

JUL 2 9 2014 

DOUGLAS E. ARPERT 

U.S. MAGISTRATE JUDGE 

&;: Helsinn Healthcare S.A., et. a/. v. Dr. Reddy's Laboratories, Ltd.~ et al. 

Ciyil Ac1ion )Sg, 11-3962 (MLC)CDEA) 

Dear Judge Arpert: 

This finn, together with Paul Hastings LLP and Loeb & Loeb LLP, represents Plaintiffs 

Helsinn Healthcare S.A. and Roche Palo Alto LLC ("Plaintiffs") in the above-captioned matter. 

In light of certain pending discovery issues that the parties are still working to resolve, 

the parties have agreed to a modest adjustment to the schedule in this case. Accordingly, 

enclosed for Your Honor's consideration is the parties' proposed amended case schedule, 

Consistent with Your Honor•s usual preference, we have included blank spaces for the insertion 

of dates for periodic telephone status conferences with the Court, which could displace any 

currently scheduled teleconferences. If this meets with the Court's approval, we respectfully 

request that Your Honor sign the below form of endorsement and enter the schedule on the 

docket. 

Thank you for Your Honor's kind attention to this matter. 

Respectfully yours, 

w~c6~ 

William c. Baton 

cc: All Counsel (via e-mail) 

SO ORDERED on this 1C'ctay of ..:f'twj • 2014. 

Ono Rivc:rfronL PluJ, Sl.lho 1!20 • Nowarlc, NJ 0'7102·5426 • Phone· (971) 216·d'700 • Pu: (PH) 286·UOO 

DILAWAII! MA1W1.ANT) t-r!W 1!UIV N!W '1(011.1( UW'NS'\"LVANIA WASHlNOTON, DC 

A t:I!L ... ~o\RI LIMJT!T> L7Ain.T'T"t' PAl'I'NIUJftP 

Case 3:11-cv-03962-MLC-DEA Document 184 Filed 07/31/14 Page 1 of 3 PageID: 4638
07/28/2014 18:55 FAX 19732888800 

'Y 

SAULEWING 

Helslnn et al. v. Dr. Reddy's Labs. et al. (D.N.J.) 

Proposed Consolidated 11·03962/13·05815 Schedule 

' ' .~ .:~ r,." ··'£ ~ell 't ~· · . . : C:umat$ehtMIUie · · Propned Schedule 

Close of fact discovery July 22, 2014 July 22_, 2014' 

Meet and Confer Deadline to propose 

Markman Hearing under Local Rule July 22, 2014 July 31,2014 

4.6 

Markman Hearing Subject to Court's Subject to Court•s 

A vail ability Availability 

30 days after entry of 30 days after entry of 

Disclose any reliance on advice of Markman order, OR 2 Markman order, OR 2 

weeks before Plaintiffs weeks before Plaintiffs counsel 

serve draft Pretrial Order serve draft Pretrial Order 

text, whichever earlier text, whichever earlier 

Opening expert reports (addressing 

claims or defenses for which a party July 25, 2014 August IS, 2014 

bears the burden of proof) 

RebuttalexDertreports August 25,2014 September 15, 2014 

Reply exl)ert reports September 19, 2014 October 10,2014 

Close of expert discovery November 12.2014 November 26a 20 14 

Deadline to file dispositive motions On or before August 12, On or before 

('219 patent) 2014 SeptemberS. 2014 

Opposition briefs to dispositive Due 4 weeks after motion Due 4 weeks after motion 

motions tiled filed 

: Reply briefs to dispositive motions Due 3 weeks after Due 3 weeks after I opposition brief filed opposition brief filed 

Exchange list of legal issues November 17, 2014 December 3, 2014 

Exchange fact witness lists (aside 

from those witnesses called for 

impeaclunent purposes, only the November 24,2014 December 8. 2014 

witnesses set forth may testifY at 

trial) 

Exchange expert witness lists (no 

expert shall be permitted to testify at November 24,2014 December 8, 2014 

trial unless identified at this time) 

Exchange objections to fact and December 9. 2014 December 22, 2014 expert witness lists 

Exchan_ge exhibit lists December 19.2014 January 9. 201 S 

Exchange electronic collection of 

exhibits from parties' respective December 19, 2014 January 9, 2015 exhibit lists in a mutually acceptable 

format 

Exchange objections to the opposing January 9, 2015 January 30, 2015 party's exhibit list 

Ill 003/004 

1

Except as to any discovery relating to requests served before July 22, 2014, that is either agreed 

upon by the parties or ordered by the Court. 

2 

Case 3:11-cv-03962-MLC-DEA Document 184 Filed 07/31/14 Page 2 of 3 PageID: 4639
0 7 /2 .. 8/2 0 •1 4 1 S : 5 5 F A X 1 8 7 3 2 8 S S 8 0 0 ,. SAULEWING Ill 004/004 

Helsinn et aL v. Dt. Reddy •s Labs. et Q.L (D.N .J.) 

Proposed Consolidated 11·03962/13·05815 Schedule 

,, •.·• 

"'~~loll '"~·· .• :"'.. i"' -1 ·• ·~ \teD I f.. I ,• ',\'Ill '' ~ ' ' ·~'!. .• nUt s&edale ... :.· Pro.,Osed Scbedu·le '' 

Exchange affinnative deposition December 12, 2014 December 22, 2015 designations 

Exchange deposition counter· 

designations and objections to January 16, 201 S January 23. 2015 

affinnative designations 

Exchange objections to counter January 30, 2015 February 6, 2015 designations 

Exchange stipulation of facts for the 

issues on which the parties have the December 16, 2014 December 22, 20 14 

burden of proof 

Exchange responses to stipulation of ' 

faots January 9, 201 S January 16, 2015 

Exchange contested facts January 30,2015 February 3, 2015 

Exchange lists of the parties' Decembers. 2014 December 12, 20 14 contem'Plated motions In limine 

Meet and confer in an attempt to 

reach mutual resolutions regarding December 12~ 2014 December 19, 201 S the parties' contemplated motions in 

limine 

Serve opening motions in limine December 19.2014 January 16~ 201 S 

Serve responses to motions tn limine January 16, 2015 February 6, 2015 

Plaintiffs serve draft Pretrial Order February 6, 2015 February 13.2015 text 

Defendants serve rebuttal to February 13, 201 S February 20, 2015 Plaintiff's draft Pretrial Order text 

Proposed Final Pretrial Order Due February 20. 201 S February 27,2015 

.w Subject to Court's Subject to Court's 

Final Pretrial Conference availability; consistent availability~ consistent 

with a requested April with a requested 

20 1 S trial date April 2015 trial date 

Trial Briefs and Proposed Findings One week after Final One week after Final 

of Facts and Conclusions of Law Pretrial Conference Pretrial Conference 

Subject to Court's Subject to Court's 

Trial availability; parties will availability~ parties have 

request an April 201 S requested an April 201 S 

trial date trial date 

I 

I 

Tho Court shall conduct a teleconference on~~ 6, 1-11 rc.j J 10 : -30 411( · 

The Court shall conduct a teleco!iferen~ on 1 J ~ S: kJ f.~ aZ .X'·~ 

.ej( TheCourtshallconduc1f:ele~~e.Ji~ c.e.. dn-ll(a-cck. ~~ ~drf ai I{!(Jf}t:Ue( 

3 

Case 3:11-cv-03962-MLC-DEA Document 184 Filed 07/31/14 Page 3 of 3 PageID: 4640