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

Filing 388

DECLARATION re 386 Memorandum in Support of Motion,, 385 MOTION to Strike Belately Disclosed Invalidity and Unenforceability Allegations and for More Time to Respond to Roche's Expert Reports OF DEBORAH E. FISHMAN by Amgen Inc.. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4, Part 1 of 2# 5 Exhibit 4, Part 2 of 2# 6 Exhibit 5# 7 Exhibit 6# 8 Exhibit 7# 9 Exhibit 8# 10 Exhibit 9# 11 Exhibit 10# 12 Exhibit 11# 13 Exhibit 12# 14 Exhibit 13# 15 Exhibit 14# 16 Exhibit 15# 17 Exhibit 16# 18 Exhibit 17# 19 Exhibit 18)(Gottfried, Michael)

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Amgen Inc. v. F. Hoffmann-LaRoche LTD et al Doc. 388 Case 1:05-cv-12237-WGY Document 388 Filed 04/13/2007 Page 1 of 3 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 DEBORAH E. FISHMAN IN SUPPORT OF PLAINTIFF AMGEN INC.'S MOTION TO STRIKE BELATEDLY DISCLOSED INVALIDITY AND UNENFORCEABILITY ALLEGATIONS AND FOR MORE TIME TO RESPOND TO ROCHE'S EXPERT REPORTS 640424_6 1 Dockets.Justia.com Case 1:05-cv-12237-WGY Document 388 Filed 04/13/2007 Page 2 of 3 I, Deborah E. Fishman, 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 a partner of 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 a letter from Aaron Hand to Peter Fratangelo, dated April 13, 2007. 4. Attached hereto as Exhibit 2 is a true and correct copy of the Electronic Court Order dated March 28, 2007. 5. Attached hereto as Exhibit 3 is a true and correct copy of Roche's Supplemental Disclosure Statement. 6. Attached hereto as Exhibit 4 is a true and correct copy of the Agreement to Abide by Protective Order signed by James W. Fisher. 7. Attached hereto as Exhibit 5 is a true and correct copy of the Agreement to Abide by Protective Order signed by Dr. Daniel Shouval. 8. Attached hereto as Exhibit 6 is a true and correct copy of the Agreement to Abide by Protective Order signed by Dr. Franklin Gaylis. 9. Attached hereto as Exhibit 7 is a true and correct copy of excerpts from Roche's Third Supplemental Privilege Log. 10. Attached hereto as Exhibit 8 is a true and correct copy of Roche's Supplemental Responses and Objections to Amgen's Third Set of Interrogatories. 11. Attached hereto as Exhibit 9 is a true and correct copy of Roche's Objections to Amgen's Fourth Notice of Deposition Pursuant to FRCP 30(b)(6). 644666_1 2 Case 1:05-cv-12237-WGY Document 388 Filed 04/13/2007 Page 3 of 3 12. Attached hereto as Exhibit 10 is a true and correct copy of a letter from Deborah Fishman to Pat Carson, dated March 23, 2007. 13. Attached hereto as Exhibit 11 is a true and correct copy of Amgen's Fourth Notice of Deposition to Defendants Pursuant to FRCP 30(b)(6). 14. Attached hereto as Exhibit 12 is a true and correct copy of Roche's Supplemental Responses and Objections to Amgen's Third Set of Interrogatories. 15. Attached hereto as Exhibit 13 is a true and correct copy of Amgen's First Set of Interrogatories. 16. Attached hereto as Exhibit 14 is a true and correct copy of an electronic Court Order dated March 27, 2007. 17. Attached hereto as Exhibit 15 is a true and correct copy of Objections of Non- Party Franklin Gaylis to Amgen's Subpoena Duces Tecum. 18. Attached hereto as Exhibit 16 is a true and correct copy of Objections of Non- Party Dr. James Fisher to Amgen's Subpoena Duces Tecum. 19. Attached hereto as Exhibit 17 is a true and correct copy of a letter from Deborah Fishman to Pat Carson dated January 19, 2007. 20. Attached hereto as Exhibit 18 is a true and correct copy of Roche's Fifth Supplemental Privilege Log. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Signed this 13th day of April, 2007. /s/ Deborah E. Fishman Deborah E. Fishman 640424_6 3

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