Takeda Pharmaceutical Co., Ltd. et al v. Sandoz, Inc.

Filing 35

STIPULATION AND ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE. Joint Case Management Statement due by 5/25/2012. Case Management Conference re-set for 6/1/2012 at 01:30 PM in Courtroom G, 15th Floor, San Francisco. Signed by Judge Joseph C. Spero on 4/26/12. (klhS, COURT STAFF) (Filed on 4/27/2012)

1

7

JEFFREY I. WEINBERGER (SBN 056214)
[e-mail]
TED G. DANE (SBN 143195)
[e-mail]
HEATHER E. TAKAHASHI (SBN 245845)
[e-mail]
ERIN J. COX (SBN 267954)
[e-mail]
MUNGER, TOLLES & OLSON LLP
355 South Grand Avenue, 35th Floor
Los Angeles, CA 90071-1560
Telephone: [phone]
Facsimile: [phone]

8

Attorneys for Plaintiffs

9

TAKEDA PHARMACEUTICAL CO., LTD.,
TAKEDA PHARMACEUTICALS U.S.A., INC.,
TAKEDA PHARMACEUTICALS LLC, AND
TAKEDA PHARMACEUTICALS AMERICA,
INC.

2
3
4
5
6

10
11
12

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

13
14
15
16

TAKEDA PHARMACEUTICAL CO., LTD.,
TAKEDA PHARMACEUTICALS U.S.A., INC.,
TAKEDA PHARMACEUTICALS LLC, AND
TAKEDA PHARMACEUTICALS AMERICA,
INC.,

Case No. 3:12-cv-00446 JCS
STIPULATION TO CONTINUANCE OF
INITIAL CASE MANAGEMENT
CONFERENCE; [PROPOSED] ORDER
THEREON

Plaintiffs,

17
18

v.

19

SANDOZ INC.,

20

Defendant.

21
22
23
24
25
26
27
28
STIPULATION TO CONTINUANCE OF INITIAL
CASE MANAGEMENT CONFERENCE; [PROPOSED]
ORDER THEREON

1

Plaintiffs Takeda Pharmaceutical Company Limited, Takeda Pharmaceuticals U.S.A., Inc.,

2

Takeda Pharmaceuticals LLC, and Takeda Pharmaceuticals America, Inc. (collectively, “Takeda”),

3

and Defendant Sandoz Inc. (“Sandoz”) hereby stipulate through their respective attorneys as

4

follows:

5

WHEREAS, on February 27, 2012, the Court issued an Order Setting Case Management

6

Conference in the above-captioned action, scheduling the Initial Case Management Conference for

7

May 4, 2012 at 1:30 p.m.;

8

WHEREAS, Sandoz has informed Takeda that it is seeking new trial counsel;

9

WHEREAS, the parties jointly request a continuance of the Case Management Conference

10
11
12
13

to allow Sandoz sufficient time to obtain new trial counsel;
WHEREAS, the parties agree that Friday, June 1, 2012, at 1:30 p.m. is a mutually agreeable
date for a rescheduled Initial Case Management Conference; and
WHEREAS, the parties further agree that they could meet the deadlines for events leading

14

up to the Initial Case Management Conference in a more orderly fashion if that Conference were

15

postponed until June 1, 2012.

16

NOW THEREFORE, IT IS HEREBY STIPULATED that, subject to the Court’s approval,

17

the Initial Case Management Conference shall be held on Friday, June 1, 2012, at 1:30 p.m. and the

18

other dates in the Corrected Order Setting Initial Case Management Conference and ADR

19

Deadlines are continued accordingly.

20
21

Respectfully Submitted,
DATED: April 25, 2012

MUNGER, TOLLES & OLSON LLP

22
23

By:

24

/s/ Heather E. Takahashi
HEATHER E. TAKAHASHI

Attorneys for Plaintiffs
TAKEDA PHARMACEUTICAL CO., LTD.,
TAKEDA PHARMACEUTICALS U.S.A.,
INC., TAKEDA PHARMACEUTICALS LLC,
AND TAKEDA PHARMACEUTICALS
AMERICA, INC.

25
26
27
28
2

STIPULATION TO CONTINUANCE OF INITIAL
CASE MANAGEMENT CONFERENCE; [PROPOSED]
ORDER THEREON

1

DATED: April 25, 2012

DUANE MORRIS LLP

2
3

By:

/s/ Jessica E. La Londe
JESSICA E. LA LONDE

4

Attorneys for Defendant
SANDOZ INC.

5
6

Judge Jo

seph C.

Spero

R NIA

26
DATED: April _____, 2012

H

LI

RT

THE HONORABLE JOSEPH C. SPERO
UNITED E R
STATES DISTRICT JUDGE
C

12

A

9

FO

11

RT
U
O

10

NO

PURSUANT TO STIPULATION, IT IS SO ORDERED.

ISTRIC
ES D
TC
AT
T

UNIT
ED

8

S

7

N

13

F
D IS T IC T O
R

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
3

STIPULATION TO CONTINUANCE OF INITIAL
CASE MANAGEMENT CONFERENCE; [PROPOSED]
ORDER THEREON

Filer’s Attestation

1
2

I, Heather Takahashi, am the ECF user whose identification and password are

3

being used to file this STIPULATION TO CONTINUANCE OF INITIAL CASE

4

MANAGEMENT CONFERENCE. In compliance with General Order 45.X.B, I

5

hereby attest that the other above-named signatory concurs in this filing.

6

DATED: April 25, 2012

7
/s/ Heather E. Takahashi

8
9
10
13851188.1

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
4

STIPULATION TO CONTINUANCE OF INITIAL
CASE MANAGEMENT CONFERENCE; [PROPOSED]
ORDER THEREON