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

Filing 1050

DECLARATION re #1048 Brief, #1049 Brief of Cherie St. Jean in Support of Amgen Inc.'s Bench Memoranda Regarding The Authentication of January 11, 1984 Telex and January 16, 1984 Letter by Amgen Inc.. (Rich, Patricia)

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

Doc. 1050

Case 1:05-cv-12237-WGY

Document 1050

Filed 09/12/2007

Page 1 of 4

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 CHERIE ST. JEAN IN SUPPORT OF AMGEN INC.'S BENCH MEMORANDA REGARDING THE AUTHENTICATION OF JAN. 11, 1984 TELEX AND JAN. 16, 1984 LETTER

786991

Dockets.Justia.com

Case 1:05-cv-12237-WGY

Document 1050

Filed 09/12/2007

Page 2 of 4

I, Cherie St. Jean, declare as follows: 1. I am employed as a Senior Specialist Paralegal by AMGEN INC. My office

address is One Amgen Center Drive, Thousand Oaks, California 91320. 2. I have been a paralegal with AMGEN INC. since June 1997. My responsibilities

have been substantially the same since I began my employment with AMGEN INC. 3. As a paralegal, I have been responsible for and have overseen the collection of

documents relevant to intellectual property litigation involving the Lin U.S. patents and foreign counterpart patents, as well as the receipt, storage and retention of documents and exhibits related to worldwide intellectual property litigation involving the Lin patents. In performing my job duties I have acquired an understanding of how AMGEN INC. receives, stores, retains, and produces documents related to worldwide intellectual property litigation involving the Lin U.S. patents and foreign counterpart patents. 4. I understand that each of the documents (without the AM-ITC production

numbers) listed below were filed publicly and made of record in the Amgen v. Chugai, No. 872617-Y (D. Mass.) litigation: BAH GVC FJX GVK 5. AM-ITC 00186476 AM-ITC 00168188 AM-ITC 00186477 AM-ITC 00346974 AM-ITC 00186476 AM-ITC 00168188 AM-ITC 00186481 AM-ITC 00346978

Because these documents relate to intellectual property litigation involving Dr.

Lin's patents, in accordance with Amgen's custom and practice, on information and belief, Amgen has maintained each of these documents in its possession, custody, and control in AMGEN INC.'s Law Department or in offsite storage since the time that these documents were made of record in the Amgen v. Chugai litigation. 6. I understand that excluding the addition of the production number, confidentiality

legend or trial exhibit number related to the current proceedings, each document listed below was collected from Amgen's Law Department or from offsite storage under Amgen's control,

786991

1

Case 1:05-cv-12237-WGY

Document 1050

Filed 09/12/2007

Page 3 of 4

affixed AM-ITC production numbers, and produced to Roche in this litigation, and each was a true and accurate copy of the document or exhibit contained in AMGEN INC.'s Law Department or offsite storage under Amgen's control.

I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Signed this 12th day of September, 2007. By: _/s/_Cherie St. Jean________ Cherie St. Jean

786991

2

Case 1:05-cv-12237-WGY

Document 1050

Filed 09/12/2007

Page 4 of 4

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/ Patricia R. Rich Patricia R. Rich

786991

3