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Apotex Corp. v. Hospira Healthcare India Private Ltd.

United States District Court, S.D. New York

January 3, 2020

APOTEX CORP., Plaintiff,
v.
HOSPIRA HEALTHCARE INDIA PRIVATE LIMITED and HOSPIRA INC., Defendants.

          LETTER OF REQUEST FOR INTERNATIONAL JUDICIAL ASSISTANCE PURSUANT TO THE HAGUE CONVENTION OF MARCH 18, 1970 ON THE TAKING OF EVIDENCE IN CIVIL OR COMMERCIAL MATTERS

          Hon. Jesse M. Furman United States District Judge

         Pursuant to Federal Rule of Civil Procedure 28(b)(1)(A) and in conformity with Article 3 of the Hague Convention on the Taking of Evidence Abroad in Civil or Commercial Matters, (the "Hague Convention"), the United States District Court for the Southern District of New York (the "Court") has the honor to submit this request on behalf of Apotex Corp. ("Apotex") to The Ministry of Law and Justice.

         1. Sender:

The Honorable Jesse M. Furman, United States District Judge
United States District Court for the Southern District of New York
Daniel Patrick Moynihan United States Courthouse
500 Pearl Street
New York, NY 10007-1312.

         2. Central Authority of the Requested State:

Central Authority
The Ministry of Law and Justice
Department of Legal Affairs
4th Floor A-Wing, Shastri Bhavan
New Delhi
110 001 India

         3. Person to Whom the Executed Request is to be Returned:

James W. Matthews
Foley & Lardner LLP
111 Huntington Avenue, Suite 2500
Boston, MA 02199-7610
Tel: (617) 342-4000
jmatthews@foley. com

         4. Specification of the date by which the requesting authority requires receipt of the response to the letter of request:

         In order for Apotex to comply with its deadline to collect evidence in the above-captioned action, the Court respectfully requests that the Central Authority issue its response in such time as to permit the Letter of Request to be fully executed before February 14, 2020.

         5. a. Requesting judicial authority:

The Honorable Jesse M. Furman, United States District Judge
United States District Court for the Southern District of New York
Daniel Patrick Moynihan United States Courthouse
500 Pearl Street
New York, NY 10007-1312.

         b. To the Competent Authority of:

The Ministry of Law and Justice
Department of Legal Affairs
Room No. 439-A, 4th Floor A-Wing, Shastri Bhavan
New Delhi
110 001 India

         c. Names of the case and any identifying number:

Apotex Corp. v. Hospira Healthcare India Private Limited and Hospira Inc., Civil Action No.: 1:18-cv-04903-JMF (United States District Court for the Southern District of New York)

         6. Names and addresses of the parties and their representatives (including ...


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