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

Filing 726

DECLARATION re #724 MOTION Defendants' Motion to Preclude Testimony from Amgen's Belatedly Disclosed Fact Witnesses (of Aldred 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)(Toms, Keith)

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

Doc. 726

Case 1:05-cv-12237-WGY

Document 726

Filed 07/16/2007

Page 1 of 2

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 PRECLUDE TESTIMONY FROM AMGEN'S BELATEDLY DISCLOSED FACT WITNESSES

I, Alfred H. Heckel, declare under penalty of perjury that: 1. I am an attorney admitted to the Bar of the State of New York and before this

Court (pro hac vice). I am an attorney at the law firm of Kaye Scholer LLP, counsel for Defendants in the above-referenced case. 2. I make this declaration in support of Defendants' Motion to Preclude Testimony

From Amgen's Belatedly Disclosed Fact Witnesses, dated July 13, 2007. 3. Attached hereto as Exhibit A is a true and correct copy of Amgen's Initial

Disclosures Pursuant to Fed.R.Civ.P. 26(a)(1), dated November 6, 2006. 4. Attached hereto as Exhibit B is a true and correct copy of Plaintiff Amgen's

Supplemental Disclosures Pursuant to Fed.R.Civ.P. 26(a)(1), dated March 8, 2007.

Dockets.Justia.com

Case 1:05-cv-12237-WGY

Document 726

Filed 07/16/2007

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5.

Attached hereto as Exhibit C is a true and correct copy of Plaintiff Amgen's

Second Supplemental Disclosures Pursuant to Fed.R.Civ.P. 26(a)(1), dated May 7, 2007. 6. Attached hereto as Exhibit D is a true and correct copy of Plaintiff Amgen's Third

Supplemental Disclosures Pursuant to Fed.R.Civ.P. 26(a)(1), dated July 10, 2007. 7. Attached hereto as Exhibit E is a true and correct copy of a letter from David

Madrid to Thomas Fleming, dated July 5, 2007. Executed this 13th day of July 2007 at New York, NY.

/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 paper copies will be sent to those indicated as non-registered participants on the abovereferenced date. /s/ Keith E. Toms______________ Keith E. Toms
03099/00501 704774.1

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