Free Motion for Issuance of Letters Rogatory - District Court of Delaware - Delaware

Case 1:04—cv—00171-GI\/IS Document 60-4 Filed 07/29/2005 Page1 0f3
EXHIBIT B

Case 1 :04-cv-00171-GIVIS Document 60-4 Filed 07/29/2005 Page 2 of 3
Morgan, lewis & Bocklus up ‘
101 Park Avenue
NewYork,NY10178·0050 CBUNSELOSS A,]. LA`,
Tel: 212.309.6000
Fax: 2l2.309.6001
www.m¤rganIewis.ccm
¥h¤mas J. Puppa
Associate
2t2.2oe.2i te .
[email protected]
July I2, 2005 _
VIA FACSIMILE AND FEDERAL EXPRESS
Louis Charles Chartrand
Pharinascience Inc.
61l l Ave Royalmount, Suite 100
Montréal, (QC)
H4? 2'F4
Canada
Re: Request for Assistance with Document Collection
Dear ; Mr. Chartrand
I am counsel for Glaxo in a pending U.S. litigation captioned Glaxo Group Limited v. Teva
Pharmaceuticals USA, Inc. and Teva Pharmaceuticals Industries Limited (D. Delaware, Civil
Action No. 04-cv~i7l). The litigation involves a claim of infringement of a United States patent
related to ranitidine hydrochloride oral syrup. I ani writing to follow-up on the voice mail I left
for you on July 7, 2005 requesting your assistance with the collection of documents related to the
above case.
The case is currently in the discovery phase and the parties have recently been made aware of the
existence of documents at a manufacturing or development facility now owned or operated by
PendoPharm in Montréal (Quebec). This facility had initially been owned by Novopharm and
then was owned by Pangeo l’harma before its merger with Pharrnascience.
The documents we are interested in comprise only the specific documents related to the work
performed by Novopharrn or Pangeo Pharma on a rartitidioe oral solution (syrup) that
Novopharm was developing in the late 1990’s.
Any assistance you can provide in locating and producing these documents would be greatly
appreciated. My client will reimburse you for any expenses you may incur in locating or

Case 1 :04-cv-00171-GIVIS Document 60-4 Filed 07/29/2005 Page 3 of 3
Morgan Lewis
¢0U'!€$ILOI.$ .•\1’ LAY
Louis Charles Chartraod
July 12, 2005
Page 2
reviewing these documents. In addition my iirm will offer whatever assistance, legal or
paralegal, that you may desire in collecting what we believe will be a small set of documents.
Please call me to discuss the above at your earliest convenience. Thank you in advance for your
cooperation.
Very truly yours,
Thomas J. Puppa
c: John M. Beans, Esq. (Counsel for Teva)(by fascimile)

Case 1:04-cv-00171-GMS

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Case 1:04-cv-00171-GMS

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