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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`GENENTECH, INC.,
`Plaintiff,
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`C.A. No. 18-924-CFC
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`v.
`AMGEN INC.,
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`Defendant.
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`AMGEN’S MOTION TO COMPEL
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`Defendant Amgen Inc. respectfully requests that the Court compel: (1) the continued
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`deposition of inventor Dr. Sharon Baughman in view of a critical late-produced email implicating
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`Dr. Brian Leyland-Jones as inventor of the Dosing Patents; (2) production of an unredacted form
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`of the late-produced email referenced above and originally produced on July 23, 2019; (3)
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`production of documents in the possession of Roche, Genentech’s parent entity, relating to Dr.
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`Leyland-Jones and the BO15935 clinical trial that he led; (4) denial of Genentech’s motion for a
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`protective order to prevent a deposition of Dr. Leyland-Jones; and (5) production of documents
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`and a 30(b)(6) witness related to licensing the patents-in-suit. The grounds for this motion are set
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`forth in the accompanying discovery dispute letter, and the specific relief is set forth in the
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`Proposed Order, filed herewith.
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`Case 1:18-cv-00924-CFC Document 394 Filed 10/04/19 Page 2 of 2 PageID #: 29284
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`Dated: October 4, 2019
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`Of Counsel:
`Michelle Rhyu
`Daniel Knauss
`Susan Krumplitsch
`Cooley LLP
`3175 Hanover Street
`Palo Alto, CA 94304-1130
`P (650) 843-5000
`rhyums@cooley.com
`dknauss@cooley.com
`skrumplitsch@cooley.com
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`Orion Armon
`Cooley LLP
`380 Interlocken Crescent, Suite 900
`Broomfield, CO 80021-8023
`P (720) 566-4000
`oarmon@cooley.com
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`Eamonn Gardner
`Cooley LLP
`4401 Eastgate Mall
`San Diego, CA 92121-1909
`P (858) 550-6000
`egardner@cooley.com
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`Nancy Gettel
`Amgen Inc.
`One Amgen Center Drive
`Thousand Oaks, CA 91320-1799
`P (805) 447-1000
`ngettel@amgen.com
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`212544548 v2
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`SMITH, KATZENSTEIN & JENKINS
`LLP
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`/s/ Eve H. Ormerod
`Neal C. Belgam (No. 2721)
`Eve H. Ormerod (No. 5369)
`1000 West Street, Suite 1501
`Wilmington, DE 19801
`(302) 652-8400
`nbelgam@skjlaw.com
`eormerod@skjlaw.com
`Attorneys for Defendant Amgen Inc.
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`2
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