Board of Trustees of the Leland Stanford Junior University v. Roche Molecular Systems, Inc. et al

Filing 184

Board of Trustees of the Leland Stanford Junior University v. Roche Molecular Systems, Inc. et al

Doc. 184

Case 3:05-cv-04158-MHP

Document 184

Filed 08/10/2007

Page 1 of 2

1 PRUETZ LAW GROUP LLP Adrian M. Pruetz (Bar No. 118215) 2 [e-mail] 1600 Rosecrans Avenue, 4th Floor 3 Manhattan Beach, CA 90266 Telephone: [phone] Facsimile: [phone] 5 QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP Brian C. Cannon (Bar No. 193071) 6 [e-mail] Tun-Jen Chiang (Bar No. 235165) 7 [e-mail] m 555 Twin Dolphin Drive, Suite 560 8 Redwood Shores, California 94065-2139 Telephone: [phone] Facsimile: [phone] 10 Attorneys for Defendants and Counterclaimants Roche Molecular Systems, Inc.; Roche Diagnostics 11 Corporation; and Roche Diagnostics Operations, Inc. 12 13 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA CASE NO. C-05-04158 MHP DECLARATION OF BRIAN C. CANNON IN SUPPORT OF ROCHE'S: (1) EMERGENCY MOTION TO ENFORCE COURT ORDER REGARDING EXPERT WITNESS DEPOSITION; AND (2) MOTION TO SHORTEN TIME

14 THE BOARD OF TRUSTEES OF THE LELAND STANFORD JUNIOR UNIVERSITY, 15 Plaint iff, 16 vs. 17 ROCHE MOLECULAR SYSTEMS, INC.; 18 ROCHE DIAGNOSTICS CORPORATION; ROCHE DIAGNOSTICS OPERATIONS, INC., 19 Defendants. 20 ROCHE MOLECULAR SYSTEMS, INC. 21 ROCHE DIAGNOSTICS CORPORATION; ROCHE DIAGNOSTICS OPERATIONS, INC., 22 Counterclaimants, 23 vs. 24 THE BOARD OF TRUSTEES OF THE 25 LELAND STANFORD JUNIOR UNIVERSITY; AND THOMAS MERIGAN. 26 Counterclaim Defendants. 27 28
04972/2191794.1
Eugene T. Chen, declare as follows:

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Case No. 05-CV-04158-MHP DECLARATION OF BRIAN C. CANNON Dockets.Justia.com

Case 3:05-cv-04158-MHP

Document 184

Filed 08/10/2007

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Declaration of Brian C. Cannon I am a member of the Bar of the State of California and a partner with Quinn

3 Emanuel Urquhart Oliver & Hedges, LLP, attorneys for Roche Molecular Systems, Inc, Roche 4 Diagnostics Corporation, and Roche Diagnostics Operations, Inc. ("Roche"). I am admitted to 5 practice before this Court on the above-captioned matter. I make this declaration of personal, 6 firsthand knowledge and, if called and sworn as a witness, I could and would testify competently 7 thereto. 8 2. Attached as Exhibit A is true and correct copy of an email string between me and

9 Ricardo Rodriguez, counsel for Stanford, sent dated July 23, 2007. 10 3. Attached as Exhibit B is a true and correct copy of an email from Ricardo

11 Rodriguez to me dated August 3, 2007. 12 4. Attached as Exhibit C is a true and correct copy of a letter from me to Ricardo

13 Rodriguez dated August 6, 2007. 14 5. Attached as Exhibit D is a true and correct copy of a letter from Ricardo Rodriguez

15 to me dated August 8, 2007. 16 6. Attached as Exhibit E is a true and correct copy of an email string between Ricardo

17 Rodriguez and me dated August 10, 2007. 18 19 20 21 22 23 24 25 26 27 28
04972/2191794.1

I declare under penalty of perjury that the foregoing is true and correct. Executed on August 10, 2007, in Redwood Shores, California.

________________/s/_____________________ Brian C. Cannon

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Case No. 05-CV-04158-MHP DECLARATION OF BRIAN C. CANNON