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

Filing 379

DECLARATION re #377 MOTION to Preclude Further Interference with Third-Party Discovery and Compel Production of Documents And Deposition Testimony, or in the Alternative, Motion to Strike Defendants? Defense Under 35 U.S.C. Section 271(e)(1), #378 Memorandum in Support of Motion, OF MARIO MOORE by Amgen Inc.. (Attachments: #1 Confidential Exhibit Coversheet#2 Exhibit 1#3 Exhibit 2#4 Exhibit 3# 5 Exhibit 5# 6 Exhibit 6# 7 Exhibit 7# 8 Exhibit 8# 9 Exhibit 9, Part 1 of 2# 10 Exhibit 9, Part 2 of 2# 11 Exhibit 10# 12 Exhibit 11# 13 Exhibit 12# 14 Exhibit 15# 15 Exhibit 16# 16 Exhibit 17# 17 Exhibit 18#18 Exhibit 19#19 Exhibit 20#20 Exhibit 21#21 Exhibit 22#22 Exhibit 25#23 Exhibit 26#24 Exhibit 27# 25 Exhibit 28# 26 Exhibit 29#27 Exhibit 30)(Gottfried, Michael) Additional attachment(s) added on 4/16/2007 (Paine, Matthew). Additional attachment(s) added on 4/16/2007 (Paine, Matthew).

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

Doc. 379 Att. 21

Case 1:05-cv-12237-WGY

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Filed 04/13/2007

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EXHIBIT 22

Dockets.Justia.com

From: Mark Hebert [mailto:[e-mail]] Sent: Thursday, March 29, 2007 1:18 PM To: Fishman, Deborah; [e-mail]; Carter, Krista; [e-mail] Cc: Michael Kallus; Joseph Patriss; Mark Hebert Subject: RE: Fresenius production Mario - You must be new to this. Nice to meet you. As Krista and Deborah both already know, there were 4 documents in question, and we are withholding the 4th document. - Mark

Mark J. Hebert
~ Fish & Richardson P.C. 225 Franklin Street
Boston, Massachusetts 02110-2804 Phone: [phone] Fax: [phone] NOTE: This email is for the use of the intended recipient only and may contain privileged or confidential information. If you have received this email in error, please notify the sender immediately. Thank you.

From: Moore, Mario [mailto:[e-mail]] On Behalf Of Fishman, Deborah Sent: Thursday, March 29, 2007 4:11 PM To: Mark Hebert; Fishman, Deborah; [e-mail]; Carter, Krista; [e-mail] Cc: Michael Kallus; Joseph Patriss Subject: RE: Fresenius production Mark, Thank you for the email. Please confirm that Fresenius is not withholding any other responsive documents, based on a refusal to produce or pursuant to an instruction from Roche to withhold documents. Best Regards, Mario

Mario Moore
Associate

Case 1:05-cv-12237-WGY
Day Casebeer Madrid & Batchelder LLP 20300 Stevens Creek Blvd., Suite #400 Cupertino, CA 95014 Direct: [phone] Cellular: [phone] Fax: [phone]

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Privileged & Confidential; Attorney Work Product; Attorney-Client Communication

From: Mark Hebert [mailto:[e-mail]] Sent: Thursday, March 29, 2007 11:53 AM To: Fishman, Deborah; [e-mail]; Carter, Krista; [e-mail] Cc: Mark Hebert; Michael Kallus; Joseph Patriss Subject: Fresenius production I am attaching the last 3 documents that we are producing in response to Amgen's subpoena. These are the documents that have been the subject of extensive e-mail traffic yesterday, which Roche has authorized to be produced. Please note that Roche requested a redaction on page 3027. I have asked Mr. Cousineau how we should designate these documents, but I have received no response. Perhaps he is traveling to Boston? In any event, out of an abundance of caution, I have designated these as "Highly Confidential." I'll leave it to counsel for Amgen and Roche to determine whether that designation is appropriate. - Mark

Mark J. Hebert
~ Fish & Richardson P.C. 225 Franklin Street
Boston, Massachusetts 02110-2804 Phone: [phone] Fax: [phone] NOTE: This email is for the use of the intended recipient only and may contain privileged or confidential information. If you have received this email in error, please notify the sender immediately. Thank you.

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Case 1:05-cv-12237-WGY

Document 379-22

Filed 04/13/2007

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