`32368
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`GENENTECH, INC.,
`
`Plaintiff and Counterclaim
`Defendant,
`
`C.A. No. 18-924-CFC
`PUBLIC VERSION
`
`v.
`AMGEN INC.,
`
`Defendant and
`Counterclaim Plaintiff.
`
`DECLARATION OF EAMONN GARDNER
`IN SUPPORT OF AMGEN’S RESPONSIVE LETTER TO GENENTECH’S
`MOTION TO COMPEL PRODUCTION OF DOCUMENTS
`
`
`
`Case 1:18-cv-00924-CFC-SRF Document 434 Filed 10/18/19 Page 2 of 2 PageID #:
`32369
`
`I, Eamonn Gardner, declare as follows:
`
`1.
`
`I am a partner at the law firm of Cooley LLP, counsel for Amgen Inc.
`
`in Case No. 18-cv-00924-CFC (D. Del.). I am familiar with the facts set forth herein,
`
`and if called as a witness, I could and would testify competently to those facts under
`
`oath.
`
`2.
`
`I submit this declaration in support of Amgen’s Responsive Letter to
`
`Genentech’s Motion to Compel Production of Documents.
`
`3.
`
`During Dr. Ben Dionne’s deposition, Genentech counsel asked certain
`
`questions related to testing performed by Dr. Dionne and Amgen employees at the
`
`request of counsel.
`
`4.
`
`Based on a reasonable inquiry, I understand that the only testing
`
`implicated by Genentech’s questions was testing that was done at the direction of
`
`outside trial counsel.
`
`
`
` I declare under penalty of perjury that the foregoing is true and correct to the best
`
`of my personal knowledge.
`
`
`
`By: /s/ Eamonn Gardner
`Eamonn Gardner
`
`
`213131208 v1
`
`
`
`
`
`Date: October 11, 2019
`
`
`
`
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`
`
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