No problem. The Motion to Amend was decent, but still some work to do on reply. The fact that we needed the Motion to Amend was self-inflicted and should never have happened. Now I hope Cozen and HCMC are awake and will go for the kill here; hire a second expert (with the 27M everyone gave them), and explain Exhibit J away. The first expert will also need to explain the rest of the points I raised, e.g., about temperature of combustion, as well. So I would like to see two expert declarations on HCMC's reply. Because if I were PM's lawyer, that is what is coming in 14 days from Friday. The Judge is enamored enough with Exhibit J to call an amendment "futile" (which I still don't get). So when PM raises it, HCMC will need to be prepared to attack it.
So I am expecting PM's opposition on Aug 20 and HCMC's reply on Sep 3. That is absent an extension, but given the acrimony over extensions that was displayed in PM's last filing, I doubt anyone is getting or giving an extension here.
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