Sanofi Aventis U.S., LLC et al v. Eli Lilly and Company et al

Filing 19

ORDER GRANTING STIPULATION CHANGING TIME. Signed by Judge Paul S. Grewal on April 10, 2015 re 18 . (psglc1S, COURT STAFF) (Filed on 4/10/2015) Modified on 4/10/2015 (psglc1S, COURT STAFF).

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FREDERICK BROWN, SBN 65316
[e-mail]
Gibson, Dunn & Crutcher LLP
555 Mission Street, Suite 3000
San Francisco, CA 94105-0921
Telephone:
415.393.8200
Facsimile:
415.393.8306
Y. ERNEST HSIN, SBN 201688
[e-mail]
Gibson, Dunn & Crutcher LLP
1881 Page Mill Road
Palo Alto, CA 94304-1211
Telephone:
650.849.5322
Facsimile:
650.849.5022
Attorneys for Sanofi-Aventis U.S. LLC and
Sanofi-Aventis Deutschland GmbH
GREGORY K. KLINGSPORN (203649)
NICOLAS A. FLEGEL (229360)
JORGENSON, SIEGEL, McCLURE & FLEGEL, LLP
gkkalsinf.com
[e-mail]
1100 Alma Street, Suite 210
Menlo Park, CA 94025
Telephone:
650.324.9300
Facsimile:
650.324.0227
Attorneys for IDEO LP
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
SANOFI-AVENTIS U.S. LLC and
SANOFI-AVENTIS DEUTSCHLAND
GMBH,
Plaintiffs,
v.
ELI LILLY AND COMPANY,
Defendant.

Miscellaneous Action No. CV-15-80063-PSG
JOINT STIPULATED REQUEST FOR
ORDER CHANGING TIME

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Gibson, Dunn &
Crutcher LLP

JOINT STIPULATED REQUEST FOR ORDER CHANGING TIME
CASE NO. 15-MC-80063-PSG

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This Joint Stipulated Request for an Order Changing the Deadline for IDEO LP to Produce a

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Rule 30(b)(6) Deponent is made on behalf of IDEO LP (“IDEO”), as well as Sanofi-Aventis U.S.

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LLC and Sanofi-Aventis Deutschland GmbH (collectively “Sanofi”). On March 31, 2015, this Court

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denied in part and granted in part IDEO’s motion to quash a deposition subpoena issued on behalf of

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Sanofi, and ordered IDEO to produce a Rule 30(b)(6) deponent, on topics approved by the Court, by

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April 21, 2015 for examination by Sanofi. IDEO and Sanofi have cooperated with each other, and

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with Eli Lilly and Company (“Lilly”), which is in litigation with Sanofi, but were unable to find a

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mutually available time to conduct the deposition. IDEO and Sanofi have agreed to a deposition in

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Chicago, IL on April 22, 2015. Lilly is available at that time and place as well. There have been no

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previous requested modifications to this Court’s deadline for IDEO to produce a deponent, and an

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extension to this Court’s deadline for IDEO to produce a Rule 30(b)(6) deponent would not affect the

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schedule for the case.

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Accordingly, IDEO and Sanofi jointly request that this Court’s deadline for IDEO to produce
a Rule 30(b)(6) deponent be extended to April 22, 2015.
Dated: April 9, 2015

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FREDERICK BROWN
GIBSON, DUNN & CRUTCHER LLP

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By:

/s/ Frederick Brown
Frederick Brown
FREDERICK BROWN, SBN 65316
Y. ERNEST HSIN, SBN 201688
Attorneys for Sanofi-Aventis U.S. LLC and SanofiAventis Deutschland GmbH

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Gibson, Dunn &
Crutcher LLP

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JOINT STIPULATED REQUEST FOR ORDER CHANGING TIME
CASE NO. 15-MC-80063-PSG

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CERTIFICATE OF SERVICE

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The undersigned hereby certifies that the foregoing document was filed electronically in

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compliance with Civil Local Rule 5.1, and will be served on all counsels of record who have

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consented to electronic service in accordance with Civil Local Rule 5.1 via the Court’s ECF system.

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Dated: April 9, 2015

By: /s/ Wendy Zhu

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Wendy Zhu

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Gibson, Dunn &
Crutcher LLP

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JOINT STIPULATED REQUEST FOR ORDER CHANGING TIME
CASE NO. 15-MC-80063-PSG