January 30, 2013

VIA EMAIL

John E. Flaherty

1. 913 6397003

E 9/32973971

:aOVn1cc3r1eI corn

Tonianrie J. Bongiovanni, US.MJ.

US. District Court for the District of New JerseyClarkson S. Fisher Building & US. Courthouse

402 East State Street

Trenton, New Jersey 08608

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

Clv. Action No, i1OO76O (JAPI(TJB)

Dear Judge Bongiovanni:

1cCaler & giish LLFloor Gateway Center

100 Mulberry Street

ewar. NJ 07102’4056

913622 3444

F, 973,624,7070

awwrnccarter corn

We, along with Fitzpatrick, Celia, Harper & Scinto, represent the

AstraZeneca plaintiffs in this action. in response to the email from Ms. Bray dated

January 25, 2013, and in advance of the telephone conference set for Friday,

February 1, 2013 at 2:30 pm, we write on behalf of all parties to propose a pretrialschedule for the case. The parties are in agreement on all but one schedule item,

as reflected in the “joint” proposed schedule set forth below. To the extent the

parties disagree and propose different or additional schedule items or dates, these

are set forth in separate sections below.

Joint Pro,pçsed Schedule

The parties jointly propose the following pretrial and trial schedule:

• February 19, 2013: opening expert reports

• March 25, 2013: responsive expert reports

rey expert // 4

close of expert discovery 1iX/

• Ap,rii8 2013:

(i;( ii,

• Aril 19, 2013:

• April 19, 2013: parties exchange (i) lists and copies of proposed trial

exhibits; (ii) names and addresses of trial witnesses a party will or may

call; and (iii) deposition designations

• April 26, 2013: parties exchange (i) objections to proposed trial exhibits;

(ii) objections to deposition designations; and (iii) deposition counter

designations
• Within three days after Hanmi obtains any information from the FDA

regarding the status of the approval of Hanmi’s NDA, and in any event

not later than May 2, 2013, Hanmi will notify both the Court and

AstraZeneca about such approval status and will produce any FDA

communication regarding such status promptly upon receipt by Hanmi’s

counsel, by May 2, 2013 if possible and in advance of the seven day

period provided under the Local Rules to the extent possible

• May 6, 2013: file responses to any pretrial motions

• May 6, 2013: parties exchange objections to deposition counter

designations

• May 6, 2013: parties meet and confer concerning proposed stipulated

facts

• May 10, 2013: file Final Pretrial Order, or if the Court prefers, file (i)

outline of trial proofs; (ii) lists of trial witnesses a party will or may call; (iii)

summaries of anticipated testimony of all trial witnesses; and (iv)

stipulated facts

-1’1tt

• May 13, 2013: final pretrial conference a$ cY

• May 20, 2013: submit copies of proposed trial exhibits

AIJA

• 2fi3 trial L c”

AstraZeneca’s Additional Proposed Schedule

AstraZeneca proposes one additional schedule item. In light of three

,,, j pending discovery motions, AstraZeneca proposes that any wrap-up discovery

necessitated by resolution of those motions be corn pleted by February 25, 2013, (1

Hanmi’s Response To AstraZeneca s Additional Proposed Schedule

AstraZeneca has been dealing with counsel for third party Parexel 1s

regarding AstraZeneca’s subpoena. and Hanrni has no objection to AstraZeneca ,‘/‘J

‘The three pending motions all filed by AstraZeneca are (1) a January 15 2013 letter

motion to compel Hanmi responses to requests for admission; (2) a January 9, 2013 lettermotion to compel discovery from Hanmi concerning “Patent Information Statements’

submitted to the FDA by Hanmi; and (3) a motion filed in the District of Maryland seeking to

compel discovery from Hanmi s FDA agent Parexel The first two motions are fully briefed
Respectfully submitted,

s/John E. Flaherty

John E. Flaherty

cc (via E-mail):

Counsel for Hanmi Defendants

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mbolandsughrue.com

jscherlingsughrue.com

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ryoosughruecom

SO ORDERED this 9’ day of Feburary 2013

ci

Tonianne J. Bongiovanni1JSMJ.