`33847
`
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`GENENTECH, INC.,
`
`
`
`Plaintiff,
`
`Defendant.
`
`v.
`
`AMGEN INC.
`
`
`
`
`Case No. 18-924-CFC
`
`
`
`STIPULATION AND [PROPOSED] SCHEDULE FOR PRETRIAL
`EXCHANGE
`
`Genentech, Inc. (“GNE”) and Amgen Inc. hereby stipulate, subject to the
`
`approval of the Court, to the following schedule for Pretrial Exchange:
`
`Pretrial Item
`
`Proposed Jury
`Instructions (Del. L.R.
`51.1(a))
`Meet and confer re jury
`instructions
`Final jury instructions
`File Jury Instructions
`Proposed Voir Dire (Del.
`L.R. 47.1)
`Proposed Special Verdict
`Form (Del. L.R. 51.1(c))
`Draft of PTO
`
`Date Genentech Will
`Provide
`January 10, 2020
`
`Date Amgen Will
`Provide
`No later than 11am PT,
`January 21, 2020 (redline of
`GNE draft)
`By Jan 23, 2020 (per Nov. 21 Oral Order)
`
`Jan. 27, 2020
`Jan 30, 2020 (per Nov. 21 Oral Order)
`February 10, 2020
`February 24, 2020 (redline
`of GNE draft)
`February 24, 2020 (redline
`of GNE draft)
`March 16, 2020 (redline of
`GNE draft)
`
`February 10, 2020
`
`February 28, 2020
`(Del. L.R. 16.3
`(d)(1))
`
`1
`
`
`
`Case 1:18-cv-00924-CFC-SRF Document 482 Filed 01/21/20 Page 2 of 3 PageID #:
`33848
`
`
`
`
`Initial Exhibit List (Del.
`L.R. 16.3(c)(6)) and PDF
`Copies of Exhibits1
`Witness List (Del. L.R.
`16.3(c)(7))
`Deposition Designations
`(Del. L.R. 16.3(c)(7)
`
`February 28, 2020
`
`March 3, 2020
`
`February 28, 2020
`
`March 3, 2020
`
`Mutual Exchange March 10, 2020
`
`Mutual Exchange March 13, 2020
`Mutual Exchange March 17, 2020
`
`Exchange MILS
`Objections to Deposition
`Designations and
`Deposition Counter
`designations
`Objections to Exhibits;
`Counter-exhibits (Del.
`L.R. 16(c)(6)) and PDF
`Copies of Exhibits
`Exchange MIL/
`Responses
`Objections to Deposition
`Counter-designations;
`objections to counter-
`exhibits
`Meet and Confer re PTO March 23, 2020 (per Nov. 21 Oral Order)
`Genentech Final PTO to
`March 26, 2020
`Amgen
`(per Nov. 21 Oral Order)
`Exchange MIL/Replies
`Mutual Exchange March 27, 2120
`File Final PTO
`March 30, 2020 (per Nov. 21 Oral Order)
`March 30, 2020
`File Voir Dire and Special
`Verdict Form
`File Daubert Motions
`Supplementation of
`Exhibit List for updated
`
`Mutual Exchange March 17, 2020
`
`Mutual Exchange March 20, 2020
`
`Mutual Exchange March 23, 2020
`
`April 1, 2020
`Mutual Exchange April 7, 2020
`
`
`1 In addition to PDF copies of exhibits, the parties will exchange native (Excel) versions of their exhibit lists.
`
`2
`
`
`
`Case 1:18-cv-00924-CFC-SRF Document 482 Filed 01/21/20 Page 3 of 3 PageID #:
`33849
`
`
`
`
`sales and financial data
`and documents
`Objections to Exhibits
`Added to Exhibit List
`Supplement
`File Daubert Responses
`File Daubert Replies
`Pretrial Conference
`Trial Commences
`
`
`Mutual Exchange April 10, 2020
`
`April 8, 2020
`April 13, 2020
`April 14, 2020, 4:00PM (unchanged)
`April 20, 2020, 9:00AM (unchanged)
`
`
`
`
`
`MCCARTER & ENGLISH, LLP
`
`
`/s/ Daniel M. Silver
`Michael P. Kelly (#2295)
`Daniel M. Silver (#4758)
`Alexandra M. Joyce (#6423)
`Renaissance Centre
`405 N. King Street, 8th Floor
`Wilmington, DE 19801
`(302) 984-6300
`mkelly@mccarter.com
`dsilver@mccarter.com
`ajoyce@mccarter.com
`
`Attorneys for Plaintiff Genentech, Inc.
`
`
`
`
`
`
`
`
`SMITH KATZENSTEIN & JENKINS
`LLP
`
`/s/ Neal C. Belgam
`Neal C. Belgam (#2721)
`Eve H. Ormerod (#5369)
`Jennifer M. Rutter (#6200)
`1000 West Street, Suite 1501
`Wilmington, DE 19801
`(302) 652-8400
`nbelgam@skjlaw.com
`eormerod@skjlaw.com
`jrutter@skjlaw.com
`
`Attorneys for Defendant Amgen Inc.
`
`Dated: January 21, 2020
`
`SO ORDERED this _____ day of _________________, 2020.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`______________________________
`United States District Judge
`
`3
`
`
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