`Case 1:17-cv-01407-CFC-SRF Document 602 Filed 11/26/19 Page 1 of 2 PageID #: 42887
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE DISTRICT OF DELAWARE
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`C. A. No.: 17-1407-CFC
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`GENENTECH, INC. and CITY OF HOPE,
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`Plaintiffs,
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`v.
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`AMGEN INC.,
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`Defendant.
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`UNOPPOSED MOTION AND |PROPOSED| ORDER EXTENDING IN PART
`DEADLINE TO COMPLY WITH ORDER RE BOEHRINGER DOCUMENT 12.1. 595]
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`WHEREAS, pursuant to the Court’s Order Granting Boehringer Ingelheim USA Corp.’s
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`Requested Relief Regarding the Boehringer Document (D.I. 595, “BI Order”), the deadline for
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`Amgen to certify to its compliance with the BI Order is November 25, 2019;
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`WHEREAS, Amgen separately filed a certification with regard to its document return
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`and forensic preservation obligations pursuant to the BI Order other than the cloud account
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`forensic preservation issued addressed below;
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`WHEREAS, due to the volume of data related to Amgen’s compliance with the cloud
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`accounts forensic preservation requirements of the BI Order, as well as Amgen’s ongoing
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`investigation concerning which cloud accounts should be forensically preserved, Amgen
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`requested of Boehringer additional time to comply; and
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`WHEREAS, Boehringer’s outside counsel at Kirkland & Ellis, LLP, have agreed, subject
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`to the Court’s approval, (1) to an extension of today’s deadline with respect to such forensic
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`preservation activities for cloud accounts through and including December 13, 2019, and (2) that
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`Amgen shall by December 13, 2019 file a supplemental certification reflecting the completion of
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`such forensic preservation activities for cloud accounts in compliance with the BI Order.
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`2563771 8. l
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`Case 1:17-cv-01407-CFC-SRF Document 602 Filed 11/26/19 Page 2 of 2 PageID #: 42888
`Case 1:17-cv-01407-CFC-SRF Document 602 Filed 11/26/19 Page 2 of 2 PagelD #: 42888
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`IT IS HEREBY ORDERED, that (1) the deadline for compliance with the BI Order is
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`extended in part through and including December 13, 2019 to allow Amgen additional time to
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`comply with its forensic preservation obligations for cloud accounts under the B1 Order, and that
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`(2) Amgen shall by December 13, 2019 file a supplemental certification reflecting the
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`completion of its forensic preservation obligations for cloud accounts under the BI Order.
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`Dated November 25, 2019
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`YOUNG CONAWAY STARGATT & TAYLOR, LLP
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`/s/James L. Higgins
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`Melanie K. Sharp (No. 2501)
`James L. Higgins (No. 5021)
`1000 North King Street
`Wilmington, DE 19801
`(302) 571-6600
`mshagg@ycst.com
`ihiggins@xcst.com
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`Attorneysfor Amgen Inc.
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`IT IS so ORDERED, thisfity of Nova-4” ,2019.
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`United States District J
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`ge
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`25637718J
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