Free Motion for Extension of Time to Complete Discovery - District Court of Delaware - Delaware

Case 1:05-cv-00337-SLR Document 93 Filed O4/20/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
POR THE DISTRICT OP DELAWARE
KING PHARIVIACEUTICALS RESEARCH )
AND DEVELOPMENT, INC., ASTELLAS US )
LLC, and ASTELLAS PHARMA US, INC. )
S Plaintiffs, j
v. j Civil Action No. 05-337 SLR
SICOR INC. AND SICOR g
PHARMACEUTICALS, INC., )
Defendants. j
)
STIPULATION AND PROPOSED ORDER
WHEREAS plaintiffs King Pharmaceuticals Research and Development, Inc., Astellas
US LLC and Astellas Pharma US, Inc. (collectively "Plaintiffs") and defendants Sicor Inc. and
Sicor Pharmaceuticals, Inc. (collectively "Defendants") collectively seek and jointly request to
extend the discovery deadlines set forth below, and
WHEREAS, in order to facilitate the just, speedy, and inexpensive determination of the
litigation, the parties have agreed to extend certain dates that impact discovery between the
parties but that do not impact the Court’s schedule for claim construction or any other dates or
deadlines set by the Court.
NOW, THEREFORE, IT IS STIPULATED AND AGREED, subject to the approval and
order of the Court, that: I
l. The deadline by which Plaintiffs and Defendants shall exchange expert reports on
issues for which the parties have the burden of proof is extended through and including May 26,
2006.

Case 1:05-cv-00337-SLR Document 93 Filed O4/20/2006 Page 2 of 3
2. The deadline by which Plaintiffs and Defendants shall exchange rebuttal expert
reports is extended through and including June 23, 2006.
3. The deadline by which Plaintiffs and Defendants shall conclude expert discovery
is extended through and including August 18, 2006.
4. The deadline by which Plaintiffs and Defendants shall respond to interrogatories
and requests for admissions is extended through and including April 28, 2006.
5. The deadline by which Plaintiffs shall produce Final Infringement Contentions is
extended through and including May 2, 2006.
6. The deadline by which Defendants shall produce Final Invalidity and
Non-Infringement Contentions is extended through and including May 5, 2006.
7. The deadline by which Plaintiffs shall produce Final Validity Contentions is
extended through and including May 12, 2006.
MORRIS JAMES HITCHENS & YOUNG CONAWAY STARGATT
WILLIAMS & TAYLOR, LLP
/s/ Richard K. Herrmann /s/ Monte T. Squire
Richard K. Herrmann (No. 405) John W. Shaw (No. 3362)
222 Delaware Avenue, 10th Fl. Monte T. Squire (No. 4764)
P.O. Box 2306 The Brandywine Building
Wilmington, DE 19899-2306 1000 West Street, 17th Floor
Telephone: (302)-888-6816 Wilmington, DE 19801
[email protected] Telephone: (302) 571-6600
Attorneys for Astellczs US LLC and mSQUl1`€@VCSI.CO1H
Astellczs Pharma US [nc. Attorneys for Sicor, [nc. and Sicor
P/zczrnzczceuticczls, [nc.
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Case 1:05-cv-00337-SLR Document 93 Filed O4/20/2006 Page 3 of 3
CONNOLLY BOVE LODGE & HUTZ
LLP
/s/ Paul E. Crawford
Paul E. Crawford (No. 493)
The Nemours Building
1007 North Orange Street
P.O. Box 2207
Wilmington, DE 19899-2207
Telephone: (302)—658—9141
[email protected]
Attorneys for King Plzarmczcemicczls
Reseczrclz and Development [nc.
SO ORDERED this day of , 2006.
United States District Judge
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