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

Filing 357

DECLARATION re #356 Opposition to Motion OF WENDY A. WHITEFORD In Support of Amgen Inc.'s Opposition to Defendants' Motion to Compel the Production of Documents, and Deposition Testimony Pursuant to Rule 30(b)(6), Relating to Pegylation and Aranesp by Amgen Inc.. (Gottfried, Michael)

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

Doc. 357

Case 1:05-cv-12237-WGY

Document 357

Filed 04/06/2007

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS AMGEN INC., ) ) 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. )

Civil Action No.: 1:05-cv-12237 WGY

DECLARATION OF WENDY A. WHITEFORD IN SUPPORT OF AMGEN INC.'S OPPOSITION TO DEFENDANTS' MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS, AND DEPOSITION TESTIMONY UNDER RULE 30(B)(6), RELATING TO PEGYLATION AND ARANESP® I, Wendy A. Whiteford, declare as follows: 1. I am employed by Amgen, Inc. as Senior Associate General Counsel in the

Intellectual Property and Litigation Group of Amgen's Law Department. 2. I am submitting this declaration in support of Amgen Inc.'s Opposition to

Defendants' Motion to Compel the Production of Documents, and Deposition Testimony Under Rule 30(b)(6), Relating to Pegylation and Aranesp®. I have knowledge of the following, and if called as a witness, could and would testify competently to the contents herein. 3. I understand that Defendants contend that Amgen Lab Notebook No. 1938

"concerns information regarding PEG-EPO." It does not. I have personally reviewed Lab Notebook No. 1938 and confirmed that Lab Notebook No. 1938 does not "concern information regarding PEG-EPO," EPO or pegylation. I declare, under penalty of perjury, under the laws of the United States, that the foregoing is true and correct and that this Declaration was completed at Thousand Oaks, California this 6th day of April 2007. /s/ Wendy A. Whiteford Wendy A. Whiteford 1

Dockets.Justia.com

Case 1:05-cv-12237-WGY

Document 357

Filed 04/06/2007

Page 2 of 2

CERTIFICATE OF SERVICE I hereby certify that this document filed through the Electronic Case Filing (ECF) system will be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF) and paper copies will be sent to those indicated as non registered participants on the above date. /s/ Michael R. Gottfried Michael R. Gottfried