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

Filing 427

DECLARATION re 425 MOTION to Strike Infringement Allegations in Amgen's Expert Reports on which Amgen did not Provide Discovery and to Preclude Testimony of Alfred H. Heckel 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# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J)(Toms, Keith)

Download PDF
Amgen Inc. v. F. Hoffmann-LaRoche LTD et al Doc. 427 Case 1:05-cv-12237-WGY Document 427 Filed 04/30/2007 Page 1 of 3 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS AMGEN INC., Plaintiff, vs. F. HOFFMANN-LA ROCHE LTD; ROCHE DIAGNOSTICS GmbH; and HOFFMANN-LA ROCHE INC. Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) CIVIL ACTION No.: 05-CV-12237WGY DECLARATION OF ALFRED H. HECKEL IN SUPPORT OF DEFENDANTS' MOTION TO STRIKE INFRINGEMENT ALLEGATIONS IN AMGEN'S EXPERT REPORTS ON WHICH AMGEN DID NOT PROVIDE DISCOVERY AND TO PRECLUDE TESTIMONY I, Alfred H. Heckel, declare under penalty of perjury that: 1. I am an attorney at the law firm of Kaye Scholer LLP, counsel for Defendants in the above-referenced case, and am admitted to the Bar of the State of New York and before this Court (pro hac vice). 2. I make this declaration in support of the Defendants' Motion to Strike Infringement Allegations in Amgen's Expert Reports on Which Amgen Did Not Provide Discovery and Preclude Testimony, dated April 27, 2007. 3. Attached hereto as Exhibit A is a true and correct copy of portions of Amgen Inc.'s Objections and Responses to Defendants' First Set of Requests for the Production of Documents and Things (Nos. 1-123), dated December 4, 2006. ws8F7.tmp Dockets.Justia.com Case 1:05-cv-12237-WGY Document 427 Filed 04/30/2007 Page 2 of 3 4. Attached hereto as Exhibit B is a true and correct copy of a letter from Howard Suh to Deborah Fishman, dated December 7, 2006. 5. Attached hereto as Exhibit C is a true and correct copy of a letter from William Gaede III to Howard Suh, dated December 13, 2006. 6. Attached hereto as Exhibit D is a true and correct copy of a letter from William Gaede III to Patricia Carson and Thomas Fleming, dated March 6, 2007. 7. Attached hereto as Exhibit E is a true and correct copy of a letter from William Gaede III to Peter Fratangelo, dated March 14, 2007. 8. Attached hereto as Exhibit F is a true and correct copy of Plaintiff's Objections to Defendants' First Notice of Deposition Pursuant to Rule 30(b)(6), dated February 23, 2007. 9. Attached hereto as Exhibit G is a true and correct copy of a letter from me to William Gaede III, dated January 24, 2007. 10. Attached hereto as Exhibit H is a true and correct copy of a letter from William Gaede III to me, dated January 24, 2007. 11. Attached hereto as Exhibit I is a true and correct copy of a letter from me to William Gaede III, dated March 1, 2007. 12. Attached hereto as Exhibit J is a true and correct copy of a letter from William Gaede III to me, dated March 6, 2007. ws8F7.tmp 2 Case 1:05-cv-12237-WGY Document 427 Filed 04/30/2007 Page 3 of 3 Executed this 30th day of April 2007 at Boston, Massachusetts. /s/ Alfred H. Heckel Alfred H. Heckel CERTIFICATE OF SERVICE I hereby certify that this document filed through the ECF system will be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF) and, due to the federal holiday, paper copies will be sent to those indicated as non-registered participants on April 30, 2007. /s/ Keith E. Toms Keith E. Toms 3099/501 659478.1 ws8F7.tmp 3

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?