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

Filing 261

DECLARATION re #258 MOTION for Reconsideration and Opposition re 222 Motion to Compel Production of Roche's Cell Line and Related Documents by Patricia A. Carson by F. Hoffmann-LaRoche LTD, Roche Diagnostics GmbH, Hoffmann LaRoche Inc.. (Attachments: #1 Exhibit A#2 Exhibit B#3 Exhibit C (1 of 3)#4 Exhibit C (2 of 3)#5 Exhibit C (3 of 3)#6 Exhibit D)(Toms, Keith)

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

Doc. 261

Case 1:05-cv-12237-WGY

Document 261

Filed 01/22/2007

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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 PATRICIA A. CARSON IN SUPPORT OF DEFENDANTS' MOTION FOR RECONSIDERATION AND OPPOSITION TO AMGEN'S MOTION TO COMPEL PRODUCTION OF ROCHE'S CELL LINE AND RELATED DOCUMENTS I, Patricia A. Carson, declare under penalty of perjury that: 1. I am an attorney admitted to the Bar of the State of New York, a partner at the law

firm of Kaye Scholar LLP, and counsel for Defendants in the above-referenced case. 2. I make this declaration in support of the Defendants' Motion for Reconsideration

and Opposition to Amgen's Motion to Compel Production of Roche's Cell Line and Related Documents, dated January 22, 2007. 3. Attached hereto as Exhibit A is a true and correct copy of an excerpt of the

December 15, 1999, hearing transcript from Amgen Inc. v. Hoechst Marion, et al., Civ. Action No. 97-10814-WGY.

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Dockets.Justia.com

Case 1:05-cv-12237-WGY

Document 261

Filed 01/22/2007

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4.

Attached hereto as Exhibit B is a true and correct copy of a letter from Deborah

Fishman to Patricia Carson dated January 5, 2007. 5. Attached hereto as Exhibit C is a true and correct copy of U.S. Patent No.

5,756,349, issued May 26, 1998. 6. Attached hereto as Exhibit D is a true and correct copy of a letter from Patricia

Carson to Deborah Fishman dated January 8, 2007. Executed this 22nd day of January 2007 at New York, New York.

/s/ Patricia A. Carson Patricia A. Carson CERTIFICATE OF SERVICE I hereby certify that this document filed through the ECF system will be sent electronically on the above-referenced date to the registered participants as identified on the Notice of Electronic Filing (NEF) and paper copies will be sent to those indicated as nonregistered participants on January 23, 2007. /s/ Keith E. Toms Keith E. Toms
3099/501 605026.1

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