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

Filing 1143

DECLARATION re 1140 MOTION in Limine To Exclude The Testimony Of Dr. Adrian Katz Obtained By Amgen Through Duress And Subterfuge For Lack Of Competence And Improper Expert Testimony From A Fact Witness (by Emily J. Schaffer) by F. Hoffmann-LaRoche LTD, Roche Diagnostics GmbH, Hoffmann LaRoche Inc.. (Attachments: # 1 Exhibit A, Part 1# 2 Exhibit A, Part 2# 3 Exhibit B)(Schaffer, Emily)

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Amgen Inc. v. F. Hoffmann-LaRoche LTD et al Doc. 1143 Case 1:05-cv-12237-WGY Document 1143 Filed 09/25/2007 Page 1 of 2 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS AMGEN INC., Plaintiff, vs. F. HOFFMANN-LA ROCHE, LTD; ROCHE DIAGNOSTICS GmbH; and HOFFMANN-LA ROCHE INC. Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) CIVIL ACTION No.: 05-CV-12237WGY DECLARATION OF EMILY J. SCHAFFER IN SUPPORT OF ROCHE'S MOTION IN LIMINE TO EXCLUDE THE TESTIMONY OF DR. ADRIAN KATZ OBTAINED BY AMGEN THROUGH DURESS AND SUBTERFUGE FOR LACK OF COMPETENCE AND IMPROPER EXPERT TESTIMONY FROM A FACT WITNESS I, Emily J. Schaffer, declare under penalty of perjury that: 1. I am an attorney admitted to the Bars of the Commonwealth of Massachusetts and the State of New York and this Court. I am an associate at the law firm of Bromberg & Sunstein LLP, counsel for Defendants in the above-referenced case. 2. I make this declaration in support of Roche's Motion in Limine to Exclude the Testimony of Dr. Adrian Katz Obtained by Amgen Through Duress and Subterfuge for Lack of Competence and Improper Expert Testimony From a Fact Witness. 4. Exhibit A is a true and correct copy of an excerpt from the deposition testimony of Dr. Katz dated March 30, 2007. 5. Exhibit B is a true and correct segment of the videotape of the deposition testimony of Dr. Katz dated March 30, 2007. 745394_1 Dockets.Justia.com Case 1:05-cv-12237-WGY Document 1143 Filed 09/25/2007 Page 2 of 2 Dated: Boston, Massachusetts September 25, 2007 /s/ Emily J. Schaffer Emily J. Schaffer (BBO # 653752) 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 (NEF). Pursuant to agreement of counsel dated September 9, 2007, paper copies will not be sent to those indicated as non registered participants. /s/ Emily J. Schaffer Emily J. Schaffer 03099/00501 745394.1 745394_1 2

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