Amgen Inc. v. F. Hoffmann-LaRoche LTD et al

Filing 1011

DECLARATION of Aaron R. Hand, Esq. In Support of Amgen Inc.'s Motion In Limine No. 25: Exclude Deposition Testimony From a Prior Litigation of Takaji Miyake, A Non-Party Witness Whom Roche did Not Previously Disclose by Amgen Inc.. (Attachments: #1 Exhibit 1#2 Exhibit 2#3 Exhibit 3#4 Exhibit 4)(Gottfried, Michael)

Amgen Inc. v. F. Hoffmann-LaRoche LTD et al

Doc. 1011

Case 1:05-cv-12237-WGY

Document 1011

Filed 09/06/2007

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS ) ) ) Plaintiff, ) ) v. ) ) ) F. HOFFMANN-LA ROCHE ) LTD., a Swiss Company, ROCHE ) DIAGNOSTICS GmbH, a German ) Company and HOFFMANN-LA ROCHE ) INC., a New Jersey Corporation, ) ) Defendants. ) __________________________________________) AMGEN INC.,

Civil Action No.: 05-12237 WGY

DECLARATION OF AARON R. HAND, ESQ. IN SUPPORT OF AMGEN INC.'S MOTION IN LIMINE NO. 25: EXCLUDE DEPOSITION TESTIMONY FROM A PRIOR LITIGATION OF TAKAJI MIYAKE, A NON-PARTY WITNESS WHOM ROCHE DID NOT PREVIOUSLY DISCLOSE

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Dockets.Justia.com

Case 1:05-cv-12237-WGY

Document 1011

Filed 09/06/2007

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I, Aaron R. Hand, declare as follows: 1. I am an attorney at the law firm of Day Casebeer Madrid & Batchelder LLP,

counsel for plaintiff Amgen Inc. I am admitted to practice law before this Court (pro hac vice) and all of the Courts of the State of California. 2. I make this declaration of my own personal knowledge. If called to testify as to

the truth of the matters stated herein, I could and would testify competently. 3. Attached hereto as Exhibit 1 is a true and correct copy of an E-mail from Graham

Pechenik to Renee DuBord Brown dated August 30, 2007, and accompanying "Trial Deposition Designations" attachment. 4. Attached hereto as Exhibit 2 is a true and correct copy of a letter from Renee

DuBord Brown to Thomas Fleming dated August 31, 2007. 5. Attached hereto as Exhibit 3 is a true and correct copy of a letter from Hank

Heckel to Renee DuBord Brown dated August 27, 2007. 6. Attached hereto as Exhibit 4 is a true and correct copy of the cover sheet to the

deposition of Takaji Miyake dated October 13 ­ 14, 1988 in Amgen Inc. v. Chugai, No. 87-2617-Y (D. Mass.), bearing production number AM-ITC 00110633.

I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Signed this 6th day of September, 2007.

By:

___/s/ Aaron R. Hand Aaron R. Hand

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Case 1:05-cv-12237-WGY

Document 1011

Filed 09/06/2007

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CERTIFICATE OF SERVICE I hereby certify that this document, filed through the ECF system will be sent electronically to the registered participants as identified on the Notice of Electronic Filing and paper copies will be sent to those indicated as non-registered participants on the above date. _____ __/s/ Michael R. Gottfried Michael R. Gottfried

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