Plaintiff's Requests for Admissions

AuthorKenneth L. Dorsney
Pages775-777
Plaintiffs Requests for Admissions
IN THE UNITED STATES DISTRICT COURT
[Name of District]
[DISTRICT COURT CAPTION]
PLAINTIFF’S FIRST SET OF REQUESTS FOR ADMISSIONS TO DEFENDANT
Pursuant to Rule 36 of the Federal Rules of Civil Procedure, and the applicable
Local Rules of the United States District Court for the District of [Name of District],
Plaintiff, [Name of Plaintiff], hereby requests that Defendant, [Name of Defendant],
separately admit or deny each of the following requests, in accordance with those rules
and the following Definitions and Instructions by serving written responses to the offices
of [Name of Counsel for Plaintiff] at [Address of Counsel for Plaintiff], on or within thirty
(30) days of service of this set of Requests for Admissions.
DEFINITIONS
1. “GenX” means the chemical compound [active ingredient] including
without limitation any salt thereof, or any preparation, formulation, pharmaceutical, or
product comprised of or containing [active ingredient].
2. “FDA” means the United States Food and Drug Administration.
3. “ANDA” means Abbreviated New Drug Application as used in 21 U.S.C.
§ 355(j) and regulations issued by the FDA pursuant thereto.
4. “Drug Product” has the meaning set forth in 35 U.S.C. § 156(f)(2).
5. “Defendant” means collectively, jointly, and severally [Name of
Defendant], and each of their officers, directors, representatives, employees, agents,
partners, corporate parents, subsidiaries, affiliates, predecessors and successors, including
any entities or persons acting on behalf of [Name of Defendant].
6. “Defendant’s ANDA” means ANDA No. 00-001 and any
supplements or amendments thereto.
7. “Defendant’s ANDA Products” means the GenX _____ Tablets, which are
the subject of Defendant’s ANDA.
8. “DEFENDANT 1,” “DEFENDANT 2” and “DEFENDANT 3” mean
and refer to documents produced in this action by Defendant bearing those Production
Numbers.
9. Any reference to a corporation or business entity includes all
entities and persons acting on the entity’s behalf as well as all affiliates, divisions,
parents, subsidiaries, predecessors and successors thereof.
10. The terms “and” and “or” shall be interpreted liberally as conjunctive,
775
A-17
dor54588_24_app_663–914.indd 775 5/5/16 5:05 PM

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