Amgen Inc. v. F. Hoffmann-LaRoche LTD et al
Filing
1175
BRIEF by F. Hoffmann-LaRoche LTD, Roche Diagnostics GmbH, Hoffmann LaRoche Inc. Defendants' Motion in Limine to preclude Plaintiaff Amgen Inc. From Offering Testimony Concerning Epogen From Fact Witness Dr. Lin Who Lacks Personal Knowledge. (Attachments: #1 Exhibit A#2 Exhibit B#3 Exhibit C#4 Exhibit D#5 Exhibit E)(Fleming, Thomas)
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Amgen Inc. v. F. Hoffmann-LaRoche LTD et al
Doc. 1175 Att. 3
Case 1:05-cv-12237-WGY
Document 1175-4
Filed 09/27/2007
Page 1 of 4
EXHIBIT C
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Case 1:05-cv-12237-WGY
Document 1175-4
Filed 09/27/2007
Page 2 of 4 3/29/2007
30(b)(6) Deposition of Fu-Kuen Lin, Ph.D. -Volume II
CONFIDENTIAL
Page 284 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS AMGEN, INC., 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. ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Civil Action No. 05-CV-12237-WGY
VIDEOTAPED DEPOSITION OF FU-KUEN LIN, PH.D. VOLUME II, PAGES 284 THROUGH 401 WESTLAKE VILLAGE, CALIFORNIA MARCH 29, 2007 (This transcript contains testimony designated confidential as per Section 5(c) of the Amended Protective Order. Please treat the entire transcript in accordance with the protective order.)
Reported by: Harry Alan Palter, C.S.R. NO. 7708
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Case 1:05-cv-12237-WGY
Document 1175-4
Filed 09/27/2007
Page 3 of 4 3/29/2007
30(b)(6) Deposition of Fu-Kuen Lin, Ph.D. -Volume II
CONFIDENTIAL
Page 377 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 please. THE REPORTER: 23. the EPO you were producing would be therapeutically effective in humans? MR. MADRID: Objection.
Outside the scope of the 30(b)(6) designation. Calls for expert-opinion testimony and calls for a legal conclusion. And the words of the question are vague and ambiguous. THE WITNESS: We -- from those data,
we would expect that it would work in the -the human -- the clinical setting. BY MS. BEN-AMI: Q Did you do any work on formulating
pharmaceutical composition for EPO? A No, I did not. Those people who had to involve in doing the clinical trial, they would know how to formulate it, yeah. Q Do you have a consulting arrangement
with Amgen, Doctor? A Yes, I do. MS. BEN-AMI: Could you mark this,
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Case 1:05-cv-12237-WGY
Document 1175-4
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