City of Winter Haven v. Cleveland Indians Baseball Company Limited Partnership

Filing 605

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION In Re: Seroquel Products Liability Litigation MDL Docket No. 1769 DOCUMENT RELATES TO ALL CASES Case No. 6:06-md-01769-ACC-DAB DECLARATION OF DENNIS J. CANTY PLAINTIFFS' MOTION FOR SANCTIONS DUE TO MISCONDUCT IN CASE-SPECIFIC DISCOVERY

I, Dennis J. Canty, hereby declare as follows: 1. I am an attorney with the firm Levin Simes Kaiser & Gornick LLP, attorneys of

record for plaintiffs in the above-referenced action. I have personal knowledge of the facts set forth herein, and would testify competently to the same if called upon to do so. 2. Attached hereto as Exhibit 1 is a copy of an Excel spreadsheet prepared at my

direction, summarizing for select cases the dates disclosures were received from AstraZeneca, various characteristics of those disclosures, and dates of plaintiff, prescribing physician and treating physician depositions. 3. Attached hereto as Exhibits 2 and 20 are true and correct copies of excerpts of

deposition transcripts taken in the captioned action. 4. Attached hereto as Exhibits 3, 11 and 25 are true and correct copies of hearing

transcripts in the captioned action. 5. Attached hereto as Exhibits 4 and 5 are true and correct copies of Orders filed in

the captioned action. 6. Attached hereto as Exhibits 6-10, 12-13, 15, 19, 21-22, 27 are excerpts of

disclosures received by this office on the dates indicated therein.

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7.

Attached hereto as Exhibits 14, 16-17, 19, 23-24, 26, 28-31 are true and correct

copies of correspondence sent or received by this office or by Laminack, Pirtle & Martines, LLP on the dates indicated therein. I declare under penalty of perjury that the foregoing is true and correct. Executed this 24th day of October 2007 in San Francisco, CA.

/s/ Dennis J. Canty__ Dennis J. Canty

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