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

Case 1:07-cv-00229—Gl\/IS Document 9 Filed 05/18/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
Merck & Co. Inc. )
Plaintiff; l
) Cr A. No,. 07—229—~Gl\/IS
M >
)
Ranbaxy Inc, and Ranbaxy Laboratories Limited )
Defendants i
I
STIPULATION AND ORDER
WHEREAS Defendants are requesting a thirty—day extension to move, answer or
otherwise plead in response to the complaint;
WHEREAS Counsel for Defendants represent that this extension is necessary for the
following reasons:
(I) Counsel for Defendants have just recently received this Complaint and been
retained to represent Ranbaxy in this matter and they need sufticient opportunity to consult with
their clients, one of whom is located in india, about the subject matter and anticipated response
to the Complaint; and
(2) Certain of defense counsel will be traveling outside of the country during the next
week and will be unavailable to prepare the response during that time,
WHEREAS for these reasons, counsel tbr Defendants respectfuily request that the Court
enter this stipulated Order.
WHEREAS Plaintiff is agreeable to the extension if` it will be considered to be without
prejudice to its rights to seek expedited relief or a quick triai,
arr r-3152602-1

Case 1:07-cv-00229—Gl\/IS Document 9 Filed 05/18/2007 Page 2 of 2
ET IS HEREBY S`1`PULAi`ED, by the parties, subject to the Order of the Court, that:
(E) The time for Defendants, Ranbaxy Inc, and Ranbaxy Laboratories Limited
("Det’enciants”), to move, answer or otherwise piead in response to the
Compiaint is extended to June 21, 2007,
(2) For the purposes of this lawsuit only, Defendants hereby waive, and agree
not to assert, any defense of insufficient service or service of process, or lack
of personal jurisdiction;
(3) Defendants agree that this extension is without prejudice to Plaintit`t" s right
to seek expedited reiief or a quick trial.
/5/ Adair); B. Gm/vcurz /s/ Frederic/c L. Coifre/I. 111
Mary B, Graham (#2256) Frederick L. Cottrell, HI (#2555)
Morris, Nichois, Arsht & Tunnel! LLP cottreli@rlf,corn
1201 North Market Street Richards, Layton & Finger, P.A.
P. O. Box 1347 One Rodney Square
Wilmington, DE i9899 920 North King Street
Attorneys for Plainlw Wilmington, DE i9801
3 02-65 I~7700
Dated: May 18, 2007 Attorneys for Defendmits
Dated: May E8, 2007
SO ORDERED this day of May, 2007,
Judge Gregory M, Sleet
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