`34896
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`GENENTECH, INC.,
`Plaintiffs,
`
`v.
`AMGEN INC.,
`
`Defendant.
`
`C.A. No. 18-924-CFC-SRF
`
`Original Version Filed: March 3, 2020
`Public Version Filed: March 10, 2020
`
`STIPULATION AND [PROPOSED] ORDER EXTENDING CERTAIN
`PRETRIAL SUBMISSION DEADLINES
`
`WHEREAS
`
`;
`
`WHEREAS Epiq experienced a complete and total system-wide interruption
`
`of all services (the “Epiq outage”) beginning the morning of Saturday, February
`
`29, 2020 (see attached Declaration of
`
`);
`
`WHEREAS, as a result of the Epiq outage,
`
`;
`
`WHEREAS Amgen’s Initial Exhibit List (L.R. 16.3(c)(6)) is currently due
`
`Tuesday, March 3, 2020;
`
`WHEREAS
`
`;
`
`
`
`Case 1:18-cv-00924-CFC-SRF Document 532 Filed 03/10/20 Page 2 of 3 PageID #:
`34897
`
`WHEREAS
`
`;
`
`NOW THEREFORE, it is hereby stipulated and agreed by the Parties,
`
`subject to the approval of the Court, that:
`
`Genentech, Inc. and Amgen Inc. hereby stipulate and agree, subject to the
`
`approval of the Court, to extend Amgen’s deadline for service of its Initial Exhibit
`
`List for fo ur full day s, measured from the time that
`
`.
`
`Genentech, Inc. and Amgen Inc. hereby further stipulate and agree, subject
`
`to the approval of the Court, that the deadline for service of Objections to Exhibits
`
`and Counter-Exhibits will be extended automatically such that it is fourteen days
`
`from the date Amgen’s Initial Exhibit List is served, and the deadline for service of
`
`Objections to Counter-Exhibits is extended automatically such that it is six days
`
`from the date that Counter-Exhibits are served.
`
` Genentech, Inc. and Amgen Inc. hereby further stipulate and agree, subject
`
`to the approval of the Court, to meet and confer and seek approval from the Court
`
`for further modifications to the Schedule for Pretrial Exchange as needed to
`
`address any impact to other deadlines caused by the Epiq outage.
`
`
`
`Case 1:18-cv-00924-CFC-SRF Document 532 Filed 03/10/20 Page 3 of 3 PageID #:
`34898
`
`No other deadlines set forth in the Stipulation and Schedule for Pretrial
`
`Exchange (D.I. 489) are affected by this stipulation.
`
`MCCARTER & ENGLISH, LLP
`
`SMITH, KATZENSTEIN & JENKINS 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.
`
`Dated: March 3, 2020
`
`/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.
`
`SO ORDERED this _____ day of _________________, 2020.
`
`______________________________
`United States District Judge
`
`
`
`
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