Almer v. Peanut Corporation of America

Filing 1899

Almer v. Peanut Corporation of America

Doc. 1899

IN THE UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA ST. PAUL DIVISION In Re: GUIDANT CORP. IMPLANTABLE DEFIBRILLATORS PRODUCTS LIABILITY LITIGATION EMMETT DAVID BROWN, Plaintiff, vs. GUIDANT CORPORATION, an Indiana Corporation; ENDOVASCULAR TECHNOLOGIES, INC., a California Corporation and a Division of GUIDANT CORPORATION; GUIDANT SALES CORPORATION, an Indiana Corporation; DR. LELAND B. HOUSMAN, M.D.; and DOES ONE through SIXTY, inclusive, Defendants. DECLARATION OF JEANETTE HAGGAS IN SUPPORT OF PLAINTIFF'S MOTION TO REMAND AND MOTION FOR SANCTIONS MDL No. 05-MD-1708 (DWF/AJB)

CASE No. 0:07-cv-01487

Honorable Donovan W. Frank Honorable Arthur J. Boylan

I, JEANETTE HAGGAS, declare: 1. I am an attorney duly licensed to practice law before all the Courts of the State of California. I am an associate in the law firm of Hersh & Hersh, attorneys of record for Plaintiff in this action. I have personal knowledge of the facts set forth herein and, if called as a witness, could and could competently testify thereto:

2. I make this Declaration in Support of Plaintiff's motion to remand and motion for sanctions.
-1DECLARATION OF JEANETTE HAGGAS IN SUPPORT OF PLAINTIFF'S MOTION TO REMAND AND MOTION FOR SANCTIONS

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3. Attached as Exhibit A is a true and correct copy of the Answer of Defendants Guidant Corporation, Inc., Guidant Corp., Inc., Guidant Planning, Inc., Guidant Vascular Intervention Group, Inc., Guidant CNVS, Inc., Guidant Cardiovascular System, Inc., Guidant Cardiac & Vascular Surgery, Inc., Devices for Vascular Intervention, Inc., Advanced Cardiovascular Systems, Inc., Origin Medsystems, Inc., and Endovascular Technologies, Inc., to Plaintiffs' Complaint, McQuillan v. Guidant Corp., et al., Case No. 01-21017 (N.D. Cal., filed March 11, 2002).

4. Attached as Exhibit B is a true and correct copy of the Defendants' Answer to the Complaint, Walker v. Guidant Corp., Case No. 01-21108 (N.D. Cal., filed June 9, 2003).

5. Attached as Exhibit C is a true and correct copy of the Corporate Integrity Agreement between the Office of Inspector General of the Department of Health and Human Services and Endovascular Technologies, Inc., dated June 30, 2003.

6. Attached as Exhibit D is a true and correct copy of relevant excerpts the Report of the Independent Panel of Guidant Corporation, dated March 20, 2006.

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7. I have spent a total of eleven (11) hours preparing this responsive pleading. My usual and customary billing rate is $275.00 per hour.

8. I declare under penalty of perjury under the laws of the State of Minnesota that the foregoing is true and correct, and that this declaration was executed on June 5, 2007, at San Francisco, California.

___s/ Jeanette Haggas______ JEANETTE HAGGAS, ESQ.

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