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

Filing 1085

DECLARATION re #1083 Emergency MOTION to allow Amgen to Examine Dr. Don Catlin on Monday Setember 24, or in the Alternative to take Deposition De Bene Esse of Jonathan D. Loeb by Amgen Inc.. (Attachments: #1 Exhibit A#2 Exhibit B#3 Exhibit C)(Gottfried, Michael)

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

Doc. 1085 Att. 3

Case 1:05-cv-12237-WGY

Document 1085-4

Filed 09/18/2007

Page 1 of 2

Exhibit C

Dockets.Justia.com

Case 1:05-cv-12237-WGY

Document 1085-4

Filed 09/18/2007

Page 2 of 2

From : Fishman, Deborah Sent : Friday, August 10, 2007 1 :27 PM To : TFleming@kayescholer .com Cc : Platt, Rachelle L . ; Day, Rusty ; Loeb, Jonathan ; DuBord Brown, Renee Subject : Stipulation to reduce number of live fact witnesses

Dear Tom, To streamline the presentation of evidence at trial and obviate the need for certain of these declarants as fact witnesses, will you please stipulate to the admissibility of the following: Exhibit L to the 5/11107 Catlin Report, Exhibit D (Declaration of Brian Rauch), Exhibit E (Declaration of Mark Byers), Exhibit F (Declaration of Sungae Park) as well as paragraphs 5161 of the 5111107 Catlin report to lay a foundation and chain of custody for Exhibit L ; and Exhibit E to the 6/20/07 Second Supplement Expert Report of Ajit Varki, and Exhibits C (Declaration of Kenneth Aoki) and Exhibit D (Declaration of Jiang Liu) to the 6/20/07 Second Supplement Expert Report of Ajit Varki to lay a foundation for Exhibit E. I am available to discuss this proposal at your earliest convenience. Thank you, Deborah
Deborah Fishman Day Casebeer Madrid Batchelder, LLP fishmand@daycasebeer .com