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

Filing 1178

DECLARATION re #1177 Opposition to Motion, of Renee Dubord Brown in Support of Amgen's Opposition to Roche's Motion in Limine to Exclude Deposition Testimony of Dr. Leroy Hood by Amgen Inc.. (Attachments: #1 Exhibit 1, Part 1 of 6#2 Exhibit 1, Part 2 of 6#3 Exhibit 1, Part 3 of 6#4 Exhibit 1, Part 4 of 6#5 Exhibit 1, Part 5 of 6#6 Exhibit 1, Part 6 of 6#7 Exhibit 2, Part 1 of 4#8 Exhibit 2, Part 2 of 4#9 Exhibit 2, Part 3 of 4#10 Exhibit 2, Part 4 of 4#11 Exhibit 3#12 Exhibit 4)(Rich, Patricia)

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

Doc. 1178

Case 1:05-cv-12237-WGY

Document 1178

Filed 09/27/2007

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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 RENEE DUBORD BROWN IN SUPPORT OF AMGEN'S OPPOSITION TO ROCHE'S MOTION IN LIMINE TO EXCLUDE DEPOSITION TESTIMONY OF DR. LEROY HOOD

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Dockets.Justia.com

Case 1:05-cv-12237-WGY

Document 1178

Filed 09/27/2007

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I, Renee DuBord Brown, declare as follows: 1. I am an attorney at the law firm of Day Casebeer Madrid & Batchelder LLP,

counsel for plaintiff Amgen Inc. I am admitted to practice law before this Court (pro hac vice) and all of the Courts of the State of California. 2. I make this declaration of my own personal knowledge. If called to testify as to

the truth of the matters stated herein, I could and would testify competently. 3. Attached hereto as Exhibit 1 is a true and correct copy of an email I sent on July

28, 2007 to Mr. Tom Fleming of Kaye Scholer LLP, enclosing two pdf documents, identified as "Exhibit A ­ Amgen's list of witnesses who may be called live at trial" and "Exhibit B ­ Amgen's Deposition Designations for Witnesses who may be called by Designation." 4. Attached hereto as Exhibit 2 is a true and correct copy of an email I received on

August 4, 2007 from Ms. Donna Baker of Kaye Scholer LLP, enclosing a pdf document identified as "Roche's Counter Designations and Objections to Amgen's Designations." 5. Attached hereto as Exhibit 3 is a true and correct copy of a February 22, 2007

letter from Mr. Gasper J. LaRosa of Kaye Scholer LLP to Ms. Deborah Fishman of Day Casebeer Madrid & Batchelder LLP, enclosing a subpoena addressed to Dr. Leroy Hood and dated February 16, 2007. 6. Attached hereto as Exhibit 4 is a true and correct copy of the cover page of the

April 2, 2007 deposition of Dr. Leroy Hood. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Signed this 27th day of September, 2007.

By:

_/s/ Renee DuBord Brown_____ Renee DuBord Brown

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Case 1:05-cv-12237-WGY

Document 1178

Filed 09/27/2007

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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

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