Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv—00833-KAJ Document 207 Filed 03/16/2006 Page 1 of 1
ASHEY 8. GEDDES
ATTORNEYS AND COUNSELLORS AT LAW TELEPHONE
302-654-IBB8
222 DELAWARE AVENUE CSM";
P. O. BOX II5O :•.o';ss4-zosv
WILMINGTON. DELAWARE 19899
March 16, 2006
The Honorable Kent A. Jordan VIA ELECTRONIC FILING
United States District Court
844 King Street
Wilmington, DE 19801
Re: Pharmacia & Upjohrx Company v. Sicor Inc. and Sicor Pharmaceuticals Inc.
C.A. N0. 04-833-KA]
Dear Judge Jordan:
I am writing on behalf of the defendants (collectively, "Sicor") in the above action, in
connection with Your Honor’s request during the March 9, 2006 teleconference that Sicor either
file a motion to amend its pleadings, or a stipulation permitting the proposed amendment, by
today.
I am pleased to report that my co-counsel, Mr. Sigale, and plaintff’ s counsel, Mr.
Boehnen, did reach agreement today on terms pursuant to which Sicor will be able to amend its
pleadings with plaintiff s consent and without need to burden the Court with further motion
practice. However, I have been unable to reach l\/Ir. Boehnen to approve the language of our
proposed stipulated order, so I have not been able to file the doctunent today as planned and
instead will need to do so tomorrow. Since the Court has closed for the day and I no longer can
confer with Your Honor’s staff by telephone, I am electronically tiling this letter so that by
today’s deadline I at least will have alerted the Court as to our status and will have sought Your
Honor’s indulgence in comtection with a slightly later tiling than anticipated.
Respectfully,
/s/ Steven J Balick
Steven J . Balick (I.D. #2114)
SJB/dmf
167722.1
cc: Maryellen Noreika, Esquire (via electronic mail)
Daniel A. Boehnen, Esquire (via electronic mail)
Reid L. Ashinoff, Esquire (via electronic mail)

Case 1:04-cv-00833-KAJ

Document 207

Filed 03/16/2006

Page 1 of 1