UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
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In re: NEURONTIN MARKETING,
SALES PRACTICES AND
PRODUCTS LIABILITY LITIGATION
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THIS DOCUMENT RELATES TO:
PRODUCTS LIABILITY ACTIONS
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MDL Docket No. 1629
Master File No. 04-10981
Judge Patti B. Saris
Magistrate Judge Leo T.
Sorokin
UNOPPOSED MOTION FOR LEAVE TO FILE A REPLY TO PRODUCTS LIABILITY
PLAINTIFFS’ MEMORANDUM IN OPPOSITION TO DEFENDANTS’ MOTION TO
STRIKE THE EXPERT REPORT OF MICHAEL TRIMBLE, M.D., AND TO
EXCLUDE DR. TRIMBLE’S TESTIMONY
Defendants, Pfizer Inc. and Warner-Lambert Company (“Defendants”), respectfully
move for leave to file the attached Memorandum in Reply to Products Liability Plaintiffs’
(“Plaintiffs”) Memorandum in Opposition to Defendants’ Motion to Strike the Expert Report of
Michael Trimble, M.D., and to Exclude Dr. Trimble’s Testimony. The grounds for this motion
are:
1. Defendants believe that their reply memorandum will assist the Court in its
consideration of their motion to strike Dr. Trimble’s report and exclude his testimony.
2 Plaintiffs do not oppose Defendants’ motion for leave to file a reply (provided
“that a reply would be appropriately limited to issues raised in [Plaintiffs’] opposition as opposed
to new theories or arguments proffered by Defendants”).
3. The proposed reply memorandum is attached hereto.
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WHEREFORE, Defendants respectfully request leave to file the attached reply
memorandum.
Dated: November 30, 2007
DAVIS POLK & WARDWELL
By: /s/ James P. Rouhandeh
James P. Rouhandeh
450 Lexington Avenue
New York, New York 10017
(212) 450-4000
SHOOK, HARDY & BACON L.L.P.
By: /s/ Scott W. Sayler
Scott W. Sayler
2555 Grand Boulevard
Kansas City, Missouri 64108
(816) 474-6550
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HARE & CHAFFIN
By: /s/ David B. Chaffin
David B. Chaffin
160 Federal Street
Boston, Massachusetts 02110
(617) 330-5000
Attorneys for Defendants Pfizer Inc. and
Warner-Lambert Company
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CERTIFICATE OF COMPLIANCE
Pursuant to Local Rule 7.1, I certify that counsel have conferred in good faith and that
Plaintiffs’ counsel has indicated, as noted above, that Plaintiffs do not oppose this motion, with
the proviso noted above.
/s/ David B. Chaffin
CERTIFICATE OF SERVICE
I hereby certify that this document filed through the ECF system has been served
pursuant to Case Management Order #3 on November 30, 2007.
/s/ David B. Chaffin
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