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 Att. 2

Case 1:05-cv-12237-WGY

Document 1011-3

Filed 09/06/2007

Page 1 of 2

Exhibit 2

Dockets.Justia.com

Case 1:05-cv-12237-WGY

Document 1011-3

Filed 09/06/2007

Page 2 of 2

DAY CASEBEER MADRID & BATCHELDER up

20300 Stevens Creek Blvd., Suite 400 Cupertino, CA 95014 Telephone : [phone] Facsimile: [phone]

Renee Dubord Brown [phone] rbrown@ daycasebeer .com

August 31, 2007
VIA EMAIL

Thomas Fleming Kaye Scholer LLP c/o Metro Meeting Centers-Boston 101 Federal Street, 4 th Floor Boston, MA 02110 Re :
Amgen, Inc. v. F. Hoffman-La Roche, LTD., et al.

Dear Tom: On Monday, August 27, you requested complete copies of Dr . Takaji Miyake's 10/13/1988 and 10/14/1988 prior testimony from Amgen v. Chugai Pharm. Co . During the course of discovery, Amgen produced to you the portions of the transcripts that were admitted to the court. After much effort we have located the complete transcripts . Unfortunately, they are confidential and subject to the Chugai protective order . Please provide us with written consent from Chugai giving you permission to view the entire transcripts and we will immediately produce them to you . If you do not have a written consent, please provide us with the reasons why you are able to give this consent for Chugai. Regards, DAY CASEBEER MADRID & BATCHELDER LLP

Renee DuBord Brown RDB :rip