Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-00833-KAJ

Document 284-8

Filed 09/14/2006

Page 1 of 2

Case 1:04-cv-00833-KAJ Tavarez, Nancy W.
From: Sent: To: Cc: Subject: Attachments:

Document 284-8

Filed 09/14/2006

Page 2 of 2

Gugig, Michael S. Wednesday, September 13, 2006 7:58 PM Rich, Joshua Boehnen, Daniel; Ashinoff, Reid L.; Sigale, Jordan A.; Gugig, Michael S.; Baum, David R.; Moshe, Mirella; Tavarez, Nancy W.; JDay; SBalick; TLydon Sicor's MOLs Sicor's Motion in Limine to Preclude Evidence regarding Criminal Conviction.pdf; Sicor's Motion in Limine to Preclude Evidence Relating to Decisions Made by Foreign Tribunals.pdf; Sicor's Motion in limine to preclude guerra affidavit.pdf

Dear Josh: Per our conversation earlier today, attached are three of Sicor's motions in limine. We reserve our right to file two additional motions in accordance with Judge Jordan's rules based upon Pharmacia's failure to identify the trial phase in which each exhibit and witness will be used. We note for the record, that PNU's motions in limine are replete with references to Sicor's identification of the phase(s) in which each exhibit and witness would be used, and in fact rely to a great extent on Sicor's phase designations to form the basis of one or more motions. This was precisely the reason we thought we had agreed to exchange witness and exhibit lists with phasing information included. Unfortunately, Sicor has been unable to do the same because of PNU's failure in this regard. Mike Gugig Michael S. Gugig Sonnenschein Nath & Rosenthal LLP 1221 Avenue of the Americas New York, New York 10020 Phone: (212) 768-6907 Fax: (212) 768-6800 [email protected]

Sicor's Motion in Limine to Pr...

Sicor's Motion in Limine to Pr...

Sicor's Motion in limine to pr...

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