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

Filing 256

DECLARATION re #254 MOTION to Compel the Production of Documents of Keith E. Toms by F. Hoffmann-LaRoche LTD, Roche Diagnostics GmbH, Hoffmann LaRoche Inc.. (Attachments: #1 Exhibit A#2 Exhibit B#3 Exhibit C#4 Exhibit D)(Toms, Keith)

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Amgen Inc. v. F. Hoffmann-LaRoche LTD et al Doc. 256 Case 1:05-cv-12237-WGY Document 256 Filed 01/19/2007 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 KEITH E. TOMS IN SUPPORT OF DEFENDANTS' MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS I, Keith E. Toms, declare under penalty of perjury that: 1. I am an attorney admitted to the Bar of the State of Massachusetts. I am an attorney at the law firm of Bromberg & Sunstein LLP and am counsel for Defendants in the above-referenced case. 2. I make this declaration in support of the Defendants' Motion to Compel the Production of Documents, dated January 19, 2007. 3. Attached hereto as Exhibit A is a true and correct copy of a letter from William G. Gaede III to Peter Fratangelo, dated January 16, 2007. 4. Attached hereto as Exhibit B is a true and correct copy of a letter from Manvin S. Mayell to William G. Gaede III, dated January 17, 2007. 603961_1 Dockets.Justia.com Case 1:05-cv-12237-WGY Document 256 Filed 01/19/2007 Page 2 of 2 5. Attached hereto as Exhibit C is a true and correct copy of a letter from William G. Gaede III to Manvin S. Mayell, dated January 18, 2007. 6. Attached hereto as Exhibit D is a true and correct copy of a letter from Peter Fratangelo to William G. Gaede III, dated January 10, 2007. Executed this 19th day of January 2007 at Boston, Massachusetts. /s/ Keith E. Toms Keith E. Toms 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) and, due to the federal holiday, paper copies will be sent to those indicated as non-registered participants on the above-referenced date. /s/ Keith E. Toms Keith E. Toms 3099/501 603961 603961_1 2

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