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Case 2:20-cv-00337-JRG Document 245 Filed 12/16/21 Page 1 of 3 PageID #: 8669
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`SEAGEN INC.,
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`
`
`
`v.
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`Plaintiff,
`
`
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`
`
`CASE NO. 2:20-cv-00337-JRG
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`)
`)
`)
`)
`)
`)
`)
`)
`)
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`)
`)
`)
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`DAIICHI SANKYO CO., LTD.,
`
`
`Defendant, and
`
`
`ASTRAZENECA PHARMACEUTICALS
`LP and ASTRAZENECA UK LTD.,
`
`
`Intervenor-Defendants.
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`
`
`NOTICE REGARDING MOTION TO COMPEL
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`Defendant Daiichi Sankyo Company, Limited (“Daiichi Sankyo Japan”) respectfully
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`provides notice that they have conducted a search for the lab notebooks at issue as previously
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`detailed in their Opposition to Plaintiff’s Renewed Motion to Compel Production of Alleged
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`Development Documents and for Relief under Rule 37 (Dkt. No. 239). Daiichi Sankyo Japan has
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`located eight lab notebooks from Drs. Kasuya, Miyazaki, Morita, and Masuda responsive to
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`Plaintiff’s request and are diligently working on producing with an expected production by
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`December 17, 2021.
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`
`
`

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`Case 2:20-cv-00337-JRG Document 245 Filed 12/16/21 Page 2 of 3 PageID #: 8670
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`Dated: December 16, 2021
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`Respectfully submitted,
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` /s/ G. Blake Thompson
`
`Deron R. Dacus
`State Bar No. 00790553
`The Dacus Firm, P.C.
`821 ESE Loop 323, Suite 430
`Tyler, Texas, 75701
`+1 (903) 705-1117
`+1 (903) 581-2543 facsimile
`ddacus@dacusfirm.com
`
`J. Mark Mann
`State Bar No. 12926150
`mark@themannfirm.com
`G. Blake Thompson
`State Bar 24042033
`blake@themannfirm.com
`MANN | TINDEL | THOMPSON
`201 E. Howard St.
`Henderson, Texas 75654
`(903) 657-8540
`(903) 657-6003 (fax)
`
`Attorneys for Defendant Daiichi Sankyo
`Company, Limited
`
`OF COUNSEL:
`
`Preston K. Ratliff II
`Joseph M. O’Malley, Jr.
`Ashley N. Mays-Williams
`Paul Hastings LLP
`200 Park Avenue
`New York, NY 10166
`(212) 318-6000
`
`Jeffrey A. Pade
`Paul Hastings LLP
`2050 M Street NW
`Washington, DC 20036
`(202) 551-1700
`
`Attorneys for Defendant Daiichi Sankyo
`Company, Limited
`
`- 2 -
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`
`

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`Case 2:20-cv-00337-JRG Document 245 Filed 12/16/21 Page 3 of 3 PageID #: 8671
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that all counsel of record who have consented to
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`electronic service are being served with a copy of this document via electronic mail on December
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`16, 2021.
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` /s/ G. Blake Thompson
` G. Blake Thompson
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`

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