344741.1 

Mayra V. Tarantino 

mtarantino@litedepalma.com

January 8, 2013 

VIA ECF 

Honorable Tonianne J. Bongiovanni, U.S.M.J. 

U.S. District Court for the District of New Jersey 

Clarkson S. Fisher Federal Bldg. & U.S. Courthouse 

402 East State Street 

Trenton, New Jersey 08608 

Re: AstraZeneca AB, et al. v. Hanmi USA, Inc., et al. 

Civil Action No. 11-760 (JAP)(TJB) 

Dear Judge Bongiovanni: 

We, along with Sughrue Mion, PLLC, represent the Hanmi Defendants (“collectively 

Hanmi”) in the above-captioned action. Hanmi respectfully submits this letter further to the 

parties’ letters of December 20, 21, 26 and 27, 2012. 

Hanmi again requests the Court’s assistance in setting the pretrial and trial 

schedule. Based on the parties’ late December letters, Your Honor will appreciate that following 

issuance of the Court’s Markman ruling, Hanmi and AstraZeneca could not come to agreement 

on a schedule per the Court’s directive. (D.I. 256 at pp. 5:11- 7:8; 7:35-8:6 (November 28, 2012 

hearing transcript)). As reflected in Hanmi’s December 20, 2012, letter to the Court (D.I. 259), 

Hanmi sought to comply with the Court’s specific directive to work out a schedule:

But I’m wondering if what I can have you folks do is agree upon a 

schedule that gives you a period of time following a decision to 

wrap things up. Generally, I'm not fond of the “within twenty-one 

days or thirty-day” type schedule because it just is too fluid for me. 

I usually prefer firm dates. But in this situation, maybe that's 

something that I can send you folks off to agree upon. . . (Id. at 

6:22-7:3) 

Instead of following the Court’s instruction, AstraZeneca refused to discuss a 

schedule following the Markman decision. Hanmi was again met with AstraZeneca’s repeated 

letters, tactics and arguments for delay, which again are rife throughout its submissions to the 

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Honorable Tonianne J. Bongiovanni, U.S.M.J 

January 8, 2013 

Page 2 

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Court but which provide no legitimate grounds to delay trial, for reasons Hanmi has set forth 

several times. 

Hanmi thus requests Your Honor’s assistance in resetting the expert schedule – which the 

Court contemplated to be in the range of 21 or 30 days following the Markman ruling for 

opening reports (D.I. 256 at 6:22-7:3) – and setting the remaining case schedule, particularly in 

view of the looming expiration of the 30-month stay in this case on June 29, 2013, and the 

Court’s stated preference to hold a “spring-type trial” (Id. at 8:19-20; D.I. 230 (Trial in April, 

2013)) and avoid preliminary injunction proceedings (D.I. 256 at 6:9-15 and 12:1-

13:15). Indeed, in order for the case to be “tried at the end of April or in May . . . with the thirtymonth stay looming,” so that “Judge Pisano [can] do what he needs to do to try to reach that 

date” (Id. at 13: 12-15), the pretrial schedule and trial date need to be set at the Court’s early 

convenience. 

We are available should the Court wish to discuss the schedule. 

Respectfully, 

 s/Mayra V. Tarantino 

Mayra V. Tarantino 

MVT:emp 

cc: Counsel of Record (via ECF & email) 

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