Monnrs, Nrouors, ARSHT & TUNNELL
NORTH MARKET STREET
P.O. Box 1347
W1LM1NGTON, DELAWAR2 19899-1347
302 658 9200
302 658 3989 Fxx
MARYELLEN NOREIKA
302 35] 9278 November I,
302 425 3011 Fxx
1'I11'1OI`€I1
The Honorable Kent A. Jordan
United States District Court
844 King Street
Wilmington, DE 19801
Re: Pharmacia & Upjohn Company LLC v. Sicor, Inc. etal.,
C.A. N0. O4~833 QKAJ)
Dear Judge J ordan:
In advance of the conference call scheduled for 12:30 this afternoon, we wanted to
bring to the Court’s attention correspondence (attached) relating to Pharmacia's efforts to obtain
copies of the foreign patent documents requested by Sicor.
As demonstrated by the letters, Pharmacia's British patent agent provided the
documents to a British copy service (IKON—L0ndon) on October 12, i.e., the day after the last Court
conference. (Pharmacia was able to provide the documents to IKON-London quickly because U.S.
counsel had initiated the process weeks before the October 11th hearing.) Unfortunately, IKON-
London failed to complete the job as promised, despite frequent pleas and complaints, and began
providing the document copies only late last week. Even then, HCON-London failed to produce the
documents in the usable format that we requested, and, thus, we have been working with IKON-
Chicago to convert the documents into a workable format. We received the first batch of workable
documents from IKON-Chicago at 3 p.m. on Monday October 31st. The remaining documents may
not be available from IKON until Wednesday November 2nd.
We were told yesterday afternoon (Monday October 31st) that Sicor's counsel is
leaving on Wednesday November 2nd for depositions that begin in Europe next Monday November
7th, and we are endeavoring to get the documents to Sicor ASAP on a rolling basis. We expect to
begin producing the documents into Sicor's hands today, and will have the remaining documents
shipped on an expedited basis to Sicor's counsel in Italy.
Respe, tfully,
`
Case 1:04-cv—OO833-KAJ Document 149 Filed 11/O1/2005 Page 2 of 2
cc: Peter T. Dalleo, Clerk (By Hand)
Steven J. Balick, Esquire (By Hand)
Reid L. Ashin0fiQ Esquire (By Email)
Jordan A. Sigale, Esquire (By Email)
David R. Baum, Esquire (By Email)
Daniel A. Boehnen, Esquire (By Email)
Case 1:04-cv-00833-KAJ
Document 149
Filed 11/01/2005
Page 1 of 2
Case 1:04-cv-00833-KAJ
Document 149
Filed 11/01/2005
Page 2 of 2
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