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

Filing 964

DECLARATION re #963 Opposition to Motion OF AARON R. HAND 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)(Gottfried, Michael)

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Amgen Inc. v. F. Hoffmann-LaRoche LTD et al Doc. 964 Case 1:05-cv-12237-WGY Document 964 Filed 09/03/2007 Page 1 of 3 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS ) ) ) Plaintiff, ) ) v. ) ) ) F. HOFFMANN-LAROCHE ) 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 AARON R. HAND IN SUPPORT OF AMGEN INC.'S OPPOSITION TO DEFENDANTS' MOTION IN LIMINE TO PRECLUDE PLAINTIFF FROM OBJECTING TO DEPOSITION DESIGNATIONS IN LIEU OF LIVE TESTIMONY 781242_1 1 Dockets.Justia.com Case 1:05-cv-12237-WGY Document 964 Filed 09/03/2007 Page 2 of 3 I, Aaron R. Hand, declare as follows: 1. I am an attorney at the law firm of Day Casebeer Madrid & Batchelder LLP, counsel for plaintiff Amgen Inc. I am admitted to practice law before this Court (pro hac vice) and all of the Courts of the State of California. 2. I make this declaration of my own personal knowledge. If called to testify as to the truth of the matters stated herein, I could and would testify competently. 3. Attached hereto as Exhibit 1 is a true and correct copy of a letter from Renee DuBord Brown to Thomas F. Fleming, dated July 30, 2007. 4. Attached hereto as Exhibit 2 is a true and correct copy of a letter from Renee DuBord Brown to Thomas F. Fleming, dated August 2, 2007. 5. Attached hereto as Exhibit 3 is a true and correct copy of is a true and correct copy of a letter from Renee DuBord Brown to Thomas F. Fleming, dated July 30, 2007 6. Attached hereto as Exhibit 4 is a true and correct copy of an E-mail from Thomas F. Fleming to Renee DuBord Brown, dated August 15, 2007. 7. Attached hereto as Exhibit 5 is a true and correct copy of a letter from Renee DuBord Brown to Thomas F. Fleming, dated August 16, 2007. 8. Attached hereto as Exhibit 6 is a true and correct copy of a letter from Thomas F. Fleming to Deborah E. Fishman, dated August 27, 2007. 9. Attached hereto as Exhibit 7 is a true and correct copy of a letter from Thomas F. Fleming to Renee DuBord Brown, dated August 27, 2007. 10. Attached hereto as Exhibit 8 is a true and correct copy of a letter from Renee DuBord Brown to Thomas F. Fleming, dated August 27, 2007. 11. Attached hereto as Exhibit 9 is a true and correct copy of a letter from Renee DuBord Brown to Thomas F. Fleming, dated August 28, 2007. 781242_1 2 Case 1:05-cv-12237-WGY Document 964 Filed 09/03/2007 Page 3 of 3 I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Signed this 3rd day of September, 2007. By: ___/s/ Aaron R. Hand Aaron R. Hand CERTIFICATE OF SERVICE I hereby certify that this document filed through the Electronic Case Filing (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 above date. /s/ Michael R. Gottfried Michael R. Gottfried 781242_1 3

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