Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv—OO833-KAJ Document 151 Filed 1 1/O2/2005 Page 1 of 1
As1-1EY & GEDDES
ATTORNEYS AND COUNSELLORS AT LAW TELEPHONE
222 DELAWARE AVENUE °°2`°°°`°°°°
FACSIMILE
P. 0. Box I|5O :,02..,..2o,,
WILMINGTON. DELAWARE 19899
November 2, 2005
The Honorable Kent A. Jordan VIA ELECTRONIC FILING
United States District Court
844 King Street
Wilmington, DE 19801
Re: Pharmacia & Upjohn Company v. Sicor Inc. and Sicor Pharmaceuticals Inc.
C.A. No. 04-833-KAJ
Dear Judge Jordan:
We write in reply to Pharmacia & Upjohn’s October 31, 2005 letter to the Court about
privilege/work product issues (D.I. 148). It is fair to say that both parties have difficulties with
the privilege log sent by the other party, and differences about the appropriate scope of work
product and privilege assertions. Indeed, on October 26, 2005, we wrote to Pharmacia to raise
concerns and request information about Pharmacia’s own 950 page, 6,000+ entry privilege log.
(See Ex. A hereto). Pharmacia has not yet responded to our letter.
Rather than prematurely burdening the Court with these issues, Sicor’s counsel will
endeavor over the next two weeks to work Pharmacia’s counsel to attempt to narrow our
differences about each other’s respective privilege and work product assertions, before bringing
unresolved work product and privilege issues to the Court. Hopefully we can narrow, if not
eliminate, the briefmg which would be necessary to make the appropriate record to resolve these
important privilege/work product issues.
Respectfully,
/s/ John G. Day
John G. Day
J GD: nml
Attachment
163078.1
cc: Maryellen Noreika, Esquire (by hand; w/attachment)
Daniel A. Boehnen, Esquire (via electronic mail; w/attachment)
Reid L. Aslrinoff, Esquire (via electronic mail; w/attachment)

Case 1:04-cv-00833-KAJ

Document 151

Filed 11/02/2005

Page 1 of 1