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

Filing 37

Declaration of T.J. Chiang in Support of Defendants' Brief on Stanford's Waiver of Privilege filed byRoche Molecular Systems, Inc., Roche Diagnostics Corporation, Roche Diagnostics Operations, Inc., Roche Molecular Systems, Inc., Roche Diagnostics Corporation, Roche Diagnostics Operations, Inc.. (Attachments: # 1 Exhibit Exhibit A# 2 Exhibit Exhibit B# 3 Exhibit Exhibit C)(Chiang, Tun-Jen) (Filed on 5/30/2006)

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Board of Trustees of the Leland Stanford Junior University v. Roche Molecular Systems, Inc. et al Doc. 37 Case 3:05-cv-04158-MHP Document 37 Filed 05/30/2006 Page 1 of 2 1 QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP Adrian M. Pruetz (Bar No. 118215) 2 Jeffrey N. Boozell (Bar No. 199507) 865 South Figueroa Street, 10th Floor 3 Los Angeles, California 90017-2543 Telephone: (213) 443-3000 4 Facsimile: (213) 443-3100 E-Mail: adrianpruetz@quinnemanuel.com 5 jeffboozell@quinnemanuel.co m 6 7 8 9 10 Robert W. Stone (Bar No. 163513) Brian C. Cannon (Bar No. 193071) T.J. Chiang (Bar No. 235165) 555 Twin Dolphin Drive, Suite 560 Redwood Shores, California 94065 Telephone: (650) 801-5000 Facsimile: (415) 801-5100 E-Mail: robertstone@quinnemanuel.co m tjchiang@quinnemanuel.co m 11 Attorneys for Defendants and Counterclaimants Roche Molecular Systems, Inc.; Roche 12 Diagnostics Corporation; and Roche Diagnostics Operations, Inc. 13 UNITED STATES DISTRICT COURT 14 NORTHERN DISTRICT OF CALIFORNIA 15 THE BOARD OF TRUSTEES OF THE LELAND CASE NO. C-05-04158 MHP 16 STANFORD JUNIOR UNIVERSITY, 17 18 vs. Plaint iff, DECLARATION OF T.J. CHIANG IN SUPPORT OF DEFENDANTS' BRIEF ON STANFORD'S WAIVER OF THE ATTORNEY-CLIENT PRIVILEGE AND WORK PRODUCT PROTECTION CONCERNING INVENTORSHIP 19 ROCHE MOLECULAR SYSTEMS, INC.; ROCHE DIAGNOSTICS CORPORATION; ROCHE 20 DIAGNOSTICS OPERATIONS, INC., 21 Defendants. 22 ROCHE MOLECULAR SYSTEMS, INC. ROCHE DIAGNOSTICS CORPORATION; ROCHE 23 DIAGNOSTICS OPERATIONS, INC., 24 25 vs. Counterclaimants, 26 THE BOARD OF TRUSTEES OF THE LELAND STANFORD JUNIOR UNIVERSITY; AND 27 THOMAS MERIGAN. 28 Counterclaim Defendants. Case No. C-05-04158 MHP DECLARATION OF T.J. CHIANG Dockets.Justia.com Case 3:05-cv-04158-MHP Document 37 Filed 05/30/2006 Page 2 of 2 1 2 I, Tun-Jen Chiang, declare: 1 I am an attorney at law licensed to practice in the State of California and an 3 associate attorney at the firm of Quinn Emanuel Urquhart Oliver & Hedges, LLP, counsel for 4 defendants Roche Molecular Systems, Inc., Roche Diagnostics Corporation, and Roche 5 Diagnostics Operations, Inc. I make this declaration of personal, first-hand knowledge and, if 6 called and sworn as a witness, I could and would testify competently as to the following: 7 2 Attached hereto as Exhibit A is a true and correct copy o f a document in the 8 file history of United States Patent No. 6,503,705, bearing a date stamp of the United States Patent 9 and Trademark Office stating that it was received on June 6, 1995, addressed to the Commissioner 10 of Patents and Trademarks, and stating on its face that it is the Declaration of Thomas C. Merigan, 11 Jr., M.D. 12 3. Attached hereto as Exhibit B is a true and correct copy of a document in the 13 file history of United States Patent No. 6,503,705, bearing a date stamp of the United States Patent 14 and Trademark Office stating that it was received on June 6, 1995, addressed to the Commissioner 15 of Patents and Trademarks, and stating on its face that it is the Declaration of Barry W. Elledge, 16 Ph.D. 17 4. Attached hereto as Exhibit C is a true and correct copy of a document in the 18 file history of United States Patent No. 6,503,705, stating on its face that it is a Decision on 19 Petition under 37 C.F.R. 1.48(a), and stating on its face that the 1.48(a) petition to correct 20 inventorship is Granted. 21 I declare under penalty of perjury under the laws of the United States of America 22 that the foregoing is true and correct. 23 24 25 26 27 28 -1Case No. C-05-04158 MHP DECLARATION OF T.J. CHIANG Executed this 30th day of May, 2006, at Redwood Shores, California. _ ___/s/ Tun-Jen Chiang______________ Tun-Jen Chiang

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