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

Filing 277

DECLARATION re #275 MOTION to Determine the Sufficiency of Roche's Responses to Amgen's Requests for Admission of Krista M. Carter by Amgen Inc.. (Attachments: #1 Confidential Exhibits Coversheet#2 Exhibit 1#3 Exhibit 3#4 Exhibit 4#5 Exhibit 5#6 Exhibit 6#7 Exhibit 7#8 Exhibit 8#9 Exhibit 12)(Gottfried, Michael)

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

Doc. 277

Case 1:05-cv-12237-WGY

Document 277

Filed 02/13/2007

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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 LAROCHE ) INC., a New Jersey Corporation, ) ) Defendants. ) __________________________________________) AMGEN INC.,

Civil Action No.: 05-12237 WGY

DECLARATION OF KRISTA M. CARTER IN SUPPORT OF PLAINTIFF AMGEN INC.'S MOTION TO DETERMINE THE SUFFICIENCY OF ROCHE'S RESPONSES TO AMGEN'S REQUESTS FOR ADMISSION

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Dockets.Justia.com

Case 1:05-cv-12237-WGY

Document 277

Filed 02/13/2007

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I, Krista M. Carter, declare as follows: 1. I am an attorney admitted to practice law before all of the Courts of the State of

California and before this Court (pro hac vice). I am an associate with the law firm of Day Casebeer Madrid & Batchelder LLP, counsel for plaintiff Amgen Inc. in this matter. 2. I make this declaration of my own personal knowledge. If called to testify with

respect to the truth of the matters stated herein, I could and would do so competently. 3. Attached hereto as Exhibit 1 is a true and correct copy of Amgen Inc.'s First Set

of Request for Admission (Nos. 1-22) served on November 17, 2006. 4. Attached hereto as Exhibit 2 is a true and correct copy of Defendants'

Supplemental Responses to Amgen Inc.'s First Set of Request for Admission (Nos. 1-22), served on January 8, 2007. 5. Attached hereto as Exhibit 3 is a true and correct copy of a letter dated December

20, 2006 from K. Carter to T. Fleming. 6. Attached hereto as Exhibit 4 is a true and correct copy of a letter dated January

11, 2007 from K. Carter to P. Carson. 7. Attached hereto as Exhibit 5 is a true and correct copy of a letter dated January

18, 2007 from K. Carter to P. Carson. 8. Attached hereto as Exhibit 6 is a true and correct copy of a letter dated January

22, 2007 from K. Carter to P. Carson. 9. Attached hereto as Exhibit 7 is a true and correct copy of an e-mail dated

December 26, 2006 from K. Carter to P. Carson. 10. Attached hereto as Exhibit 8 is a true and correct copy of an e-mail dated

December 28, 2006 from P. Carson to D. Fishman. 11. Attached hereto as Exhibit 9 is a true and correct copy of Defendants' Responses

and Objections to Plaintiff Amgen Inc.'s First Set of Interrogatories to Defendants (Nos. 1-15), served on January 11, 2007.

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Case 1:05-cv-12237-WGY

Document 277

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12.

Attached hereto as Exhibit 10 is a true and correct copy of a document titled

"Manufacture of the Starting Material of EPO," bearing bates no. ITC-R-IND-00071125-126. 13. Attached hereto as Exhibit 11 is a true and correct copy of a document titled

"Structure of Epotein Beta," bearing bates no. ITC-R-BLA-00004659-660. 14. Attached hereto as Exhibit 12 is a true and correct copy of a letter from P. Carson

to K. Carter, dated February 12, 2007. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.

Dated: February 13, 2007

/s/

Krista M. Carter Krista M. Carter

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