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

Filing 320

MEMORANDUM in Support re #319 MOTION to Compel Deposition Testimony under Rule 30(b)(6) filed by F. Hoffmann-LaRoche LTD, Roche Diagnostics GmbH, Hoffmann LaRoche Inc.. (Attachments: #1 Exhibit A#2 Exhibit B#3 Exhibit C#4 Exhibit D#5 Exhibit E#6 Exhibit F#7 Exhibit G)(Huston, Julia)

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

Doc. 320 Att. 4

Case 1:05-cv-12237-WGY

Document 320-5

Filed 03/15/2007

Page 1 of 3

EXHIBIT D

Dockets.Justia.com

Case 1:05-cv-12237-WGY

Document 320-5

Filed 03/15/2007

Page 2 of 3

McDermott Emery
Will &

Boton Brels Chicago OOssdor london Los Angeles Miami Muich

Willam G. Gaede II
Atorney at Law

Ne York Orange County Rom Sa Diego Silico Valley Washnglo, D.C.

wgaedeilmwe.com 650.813.5035

Februar 28, 2007

VIA FACSIMILE AND E-MAIL

Thomas F. Fleming, Esq. Kaye Scholer LLP 425 Park Avenue New York, NY 10022-3598

Re: Amgen Inc. v. F. Hoffmann-La Roche Ltd., et al Case No. 05 Civ. 12237 WGY
Dear Tom:

As promised durng our meet and confer yesterday, I am providing deposition dates and Rule 30(b)(6) witness identity for some of Amgen's witnesses.

Individuals:
· Alex Lyons is available for deposition on March 22.
· Thomas Strckland - Roche requested a deposition date of

March 9. This date is most likely acceptable. We expect to confirm ths on Friday, March 2.

· Helen Torley is available for her individual deposition on March 19.
· Graham Molineux is available durng the week of

March 26.

· Fu-Kuen Un is out of the countr until March 12. We wil determine his availability
as soon as he retus.

· Daniel Vapnek is out of

the countr until next week. We wil determine his

availabilty as soon as he retus.

· Joan Egre is willng to appear voluntarly on March 23 for a non-video deposition. If Roche insists on videotaping the deposition, Dr. Egre wil require Roche to issue a
subpoena for her appearance.

Case 1:05-cv-12237-WGY
Thomas F. Fleming, Esq.
Februar 28, 2007

Document 320-5

Filed 03/15/2007

Page 3 of 3

Page 2

Rule 30(b)(6) witnesses:

Subject to our contiuing meet and confer, we offer the followig preliminar
information:

· Robert Azelby is available as Amgen's 30(b)(6) witness on Topics 19 and 20 on March 14.

· Helen Torley is available as Amgen's 30(b)(6) witness on Topics 16,22,24, and 25 (the later two topics are subject to fuer meeting and conferrng on scope) on March
20.

· Fred Manak is available as Amgen's 30(b )(6) witness on Topics 17 and 23 on March
28.

· James Daly is available as Amgen's 30(b)(6) witness on Topic 15 and 21. We are

obtag dates.
Please let me know if you are available for a fuher meet and confer on Friday morng
for additional discussion on Roche's Rule 30(b)( 6) topics.

Wiliam G. Gaede, II
cc: Mie Gottfred Esq.
Krsta Carer, Esq.

Sandip H. Patel, Esq.