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

Filing 26

Declaration of Ricardo Rogriguez in Support of Stanford University and Dr. Merigan's Response to Defendant's Proposed Discovery Plan Regarding the Contract Issues filed byBoard of Trustees of the Leland Stanford Junior University, Board of Trustees of the Leland Stanford Junior University. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J)(Rodriguez, Ricardo) (Filed on 2/27/2006)

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Board of Trustees of the Leland Stanford Junior University v. Roche Molecular Systems, Inc. et al Doc. 26 Case 3:05-cv-04158-MHP Document 26 Filed 02/27/2006 Page 1 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 COOLEY GODWARD LLP A T T O R N E Y S A T LAW PALO A L T O COOLEY GODWARD LLP STEPHEN C. NEAL (No. 170085) (nealsc@cooley.com) RICARDO RODRIGUEZ (No. 173003) (rr@cooley.com) MICHELLE S. RHYU (No. 212922) (mrhyu@cooley.com) Five Palo Alto Square 3000 El Camino Real Palo Alto, CA 94306-2155 Tel: (650) 843-5000 Fax: (650) 857-0663 Attorneys for Plaintiff and Counterclaim Defendant, THE BOARD OF TRUSTEES OF THE LELAND STANFORD JUNIOR UNIVERSITY and Counterclaim Defendant THOMAS MERIGAN UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA THE BOARD OF TRUSTEES OF THE LELAND STANFORD JUNIOR UNIVERSITY, Plaintiff, v. ROCHE MOLECULAR SYSTEMS, ET AL., Defendants. ROCHE MOLECULAR SYSTEMS, ET AL., Counterclaimants, v. THE BOARD OF TRUSTEES OF THE LELAND STANFORD JUNIOR UNIVERSITY; AND THOMAS MERIGAN, Counterclaim Defendants. Case No. C 05 04158 MHP DECLARATION OF RICARDO RODRIGUEZ IN SUPPORT OF STANFORD UNIVERSITY AND DR. MERIGAN'S RESPONSE TO DEFENDANTS' PROPOSED DISCOVERY PLAN REGARDING THE CONTRACT ISSUES 721579 v1/PA DECLARATION OF RODRIGUEZ ISO STANFORD & MERIGAN'S RESPONSE TO DEF'S PROPOSED DISCOVERY PLAN. CASE NO. C-05-04158 MHP Dockets.Justia.com Case 3:05-cv-04158-MHP Document 26 Filed 02/27/2006 Page 2 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 COOLEY GODWARD LLP A T T O R N E Y S A T LAW PALO A L T O I, Ricardo Rodriguez, declare as follows: 1. I am a partner with the law firm of Cooley Godward LLP, counsel of record for The Board of Trustees of the Leland Stanford Junior University and Thomas Merigan in the above-captioned matter. I have knowledge of the following, and if called as a witness, could and would testify competently to this declaration's contents. 2. Attached hereto as Exhibit A is a true and correct copy of Reduction in Plasma Human Immunodeficiency Virus Ribonucleic Acid after Dideoxynucleoside Therapy as Determined by the Polymerase Chain Reaction, Holodniy et al., J. Clin. Invest. 88:1755-59 (Nov. 1991). 3. Attached hereto as Exhibit B is a true and correct copy of Multicenter Evaluation of Quantification Methods for Plasma Human Immunodeficiency Virus Type 1 RNA, Lin et al, JID 170:553-62 (1994). 4. Attached hereto as Exhibit C is a true and correct copy of Association of Plasma Human Immunodeficiency Virus Type 1 RNA Level with Risk of Clinical Progression in Patients with Advanced Infection, Coombs et al., JID 174:704-12 (1996). 5. Attached hereto as Exhibit D is a true and correct copy of the Assets Purchase Agreement by and between Hoffmann-La Roche Inc. and Cetus Corporation, dated July 19, 1991. [FILED UNDER SEAL] 6. Attached hereto as Exhibit E is a true and correct copy of the Consulting Agreement between Cetus Corporation and Thomas Merigan, M.D., effective April 13, 1984. 7. Attached hereto as Exhibit F is a true and correct copy of the Material Transfer Agreement between Cetus and Thomas Merigan, M.D. and David Schwartz, M.D., Ph.D., signed February 1989. 8. Attached hereto as Exhibit G is a true and correct copy of the Visitor's Confidentiality Agreement between Cetus and Mark Holodniy, M.D., signed February 14, 1989. 9. Attached hereto as Exhibit H is a true and correct copy of the Non-Exclusive Consulting Agreement by and between Cetus Corporation and Thomas C. Merigan, M.D., effective April 19, 1991. [FILED UNDER SEAL] 721579 v1/PA 1. DECLARATION OF RODRIGUEZ ISO STANFORD & MERIGAN'S RESPONSE TO DEF'S PROPOSED DISCOVERY PLAN. CASE NO. C-05-04158 MHP Case 3:05-cv-04158-MHP Document 26 Filed 02/27/2006 Page 3 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 COOLEY GODWARD LLP A T T O R N E Y S A T LAW PALO A L T O 10. Attached hereto as Exhibit I is a true and correct copy of Detection and Quantification of Human Immunodeficiency Virus RNA in Patient Serum by Use of the Polymerase Chain Reaction, Holodniy et al., JID 163:862-66 (1991). 11. Attached hereto as Exhibit J is a true and correct copy of excerpts from the Transcript of Proceedings, conducted on February 13, 2006. 12. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct, and that this declaration was executed in Palo Alto, California on February 27, 2006. Ricardo Rodriguez 721579 v1/PA 2. DECLARATION OF RODRIGUEZ ISO STANFORD & MERIGAN'S RESPONSE TO DEF'S PROPOSED DISCOVERY PLAN. CASE NO. C-05-04158 MHP

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