Amgen Inc. v. F. Hoffmann-LaRoche LTD et al
Filing
782
DECLARATION of Deborah E. Fishman in Support of Amgen's Opposition to Defendants' Motion to Preclude Testimony from Amgen's Belatedly Disclosed Fact Witnesses by Amgen Inc.. (Attachments: #1 Exhibit 1#2 Exhibit 2#3 Exhibit 3#4 Exhibit 4#5 Exhibit 5#6 Exhibit 6#7 Exhibit 7#8 Exhibit 8#9 Exhibit 9#10 Exhibit 10#11 Exhibit 11#12 Exhibit 12#13 Exhibit 13#14 Exhibit 14#15 Exhibit 15#16 Exhibit 16#17 Exhibit 17#18 Exhibit 18#19 Exhibit 19#20 Exhibit 20#21 Exhibit 21#22 Exhibit 22#23 Errata 23#24 Exhibit 24#25 Exhibit 25#26 Exhibit 26)(Gottfried, Michael)
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Amgen Inc. v. F. Hoffmann-LaRoche LTD et al
Doc. 782 Att. 20
Case 1:05-cv-12237-WGY
Document 782-21
Filed 07/30/2007
Page 1 of 3
EXHIBIT 20
Fishman Decl. to Amgen's Opp to Motion to Preclude Testimony from Amgen's Belated Disclosed Fact Witnesses - Public
Dockets.Justia.com
Case 1:05-cv-12237-WGY
Document 782-21
Filed 07/30/2007
Page 2 of 3
DAY CASEBEER MADRID & BATCHELDER
LLP
20300 Stevens Creek Blvd ., Suite 400 Cupertino, CA 95014 Telephone : (408) 873-0110 Facsimile : (408) 873-0220
Lloyd R. Day (408) 342-4561 lrday@daycasebeer .com
May 25, 2007
VIA FACSIMILE & ELECTRONIC MAIL
Leora Ben-Ami, Esq. Kaye Scholer LLP 425 Park Avenue New York, NY 10022-3598 Re : Amgen Inc. v. F. Hoffman-Roche, Ltd., et al. (Civil Action No: 05-12237-WGY)
Dear Leora: I write to follow up on our discussion this morning regarding the schedule for expert depositions. On May 1, Roche served supplemental reports from Drs . Lowe, Spinowitz, Flavell, Kadesch and Mr . Sofocleous . On May 8, Roche served a second supplemental report from Dr . Lowe. On May 11, Roche served rebuttal reports from Drs . Cords, Klibanov, Longmore, Flavell, Imperiali, Jorgensen, and Mayersohn that included previously undisclosed non-infringement arguments. To assist with expert deposition scheduling, we write to inform you that in response to the previously undisclosed issues raised in the above reports, Amgen will submit reports responsive to the previously undisclosed issues raised in Roche's supplemental and rebuttal reports from the following experts : Mr. Kunin and Drs . Berk, Bradshaw, Goldwasser, Varki, Lodish, Katre, Orkin, Kolodner, McLawhon and Torchilin. Amgen will serve these responsive expert reports by June 1, 2007, with the exception of Dr. Lodish's responsive expert report, which it will serve by June 4, 2007 . At the same time, Amgen reserves its right to move to strike or preclude any previously undisclosed allegation or untimely expert report served by Roche in this case. In addition to the above-listed Amgen experts, Amgen will also designate one or more witnesses to replace Dr . Eschbach and will also submit responsive rebuttal report(s) as soon as possible . At present, we cannot provide you with a date certain for serving such report(s), but as I mentioned this morning, I will give you a report on our progress in locating appropriate replacement(s) within two weeks .
683337
Case 1:05-cv-12237-WGY
Document 782-21
Filed 07/30/2007
Page 3 of 3
DAY CASEBEER MADRID & BATCHELDER LLP
Leora Ben-Ami May 25, 2006 Page 2 As we discussed this morning, we should now work to schedule the depositions of both parties' respective experts in light of these responsive reports. Sincerely yours,
D SEBEER D & BATCHELDER LLP
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