Free Stipulation to EXTEND Time - District Court of Delaware - Delaware

Case 1:07-cv-00332-GMS

Document 7

Filed 11/19/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

TEVA PHARMACEUTICAL INDUSTRIES LTD. and TEVA PHARMACEUTICAL USA, INC., C.A. No. 07-332-GMS Plaintiffs, v. TORRENT PHARMACEUTICALS LTD. and TORRENT PHARMA INC., Defendants.

STIPULATED MOTION FOR EXTENSION OF TIME TO ANSWER TEVA'S COMPLAINT Plaintiffs, Teva Pharmaceuticals Industries Ltd. and Teva Pharmaceuticals USA, Inc. (collectively "Plaintiffs") and Defendants Torrent Pharmaceuticals Ltd. and Torrent Pharma Inc. (collectively "Defendants") respectfully submit the following Stipulated Motion for Extension of Time for Defendants to Answer Teva's Complaint and support this Motion as follows: 1. 2. Plaintiffs filed their Complaint on May 23, 2007. Plaintiffs effected service of the Complaint on Defendants on September

21, 2007. At this time, Defendants filed a waiver of service. 3. 2007. 4. Since the Complaint's filing, Plaintiffs and Defendants continuously have Pursuant to the waiver Defendants' Answer is currently due November 20,

been working to negotiate an amicable resolution to Plaintiffs' claims.

Case 1:07-cv-00332-GMS

Document 7

Filed 11/19/2007

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5.

As these amicable negotiations continue to progress, Plaintiffs and

Defendants together seek an additional thirty (30) day extension to Defendants' Answer Date until December 20, 2007 in an attempt to complete these negotiations. 6. 7. This is the first extension sought by Defendants. This extension will not prejudice either Plaintiffs or Defendants and is

sought jointly in an attempt to resolve this matter amicably without Court's intervention. WHEREFORE, Plaintiffs Teva Pharmaceuticals Limited and Teva Pharmaceuticals USA, Inc. and Defendants Torrent Pharmaceutical, Ltd. and Torrent Pharma, Inc. respectfully request this Court enter an Order extending Defendants' Answer date until December 20, 2007.

/s/ John W. Shaw John W. Shaw (No. 3362) YOUNG, CONAWAY, STARGATT & TAYLOR, LLP The Brandywine Building 1000 West Street, 17th Floor Wilmington, DE 19899-0391 (302) 571-6600 [email protected] Attorneys for Plaintiffs Teva Pharmaceuticals Industries Limited and Teva Pharmaceuticals USA, Inc. Dated: November 19, 2007

/s/ Francis J. Murphy Francis J. Murphy, (No. 223) MURPHY & LANDON, P.A. 1011 Centre Road, Suite 210 Wilmington, Delaware 19805 (302) 472-8103 [email protected] Attorneys for Defendants Torrent Pharma Inc. and Torrent Pharmaceuticals Ltd.

SO ORDERED this ___ day of ___________________, 2007,

United States District Judge

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