`34919
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`GENENTECH, INC.,
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`Plaintiff and Counterclaim Defendant,
`
`v.
`
`AMGEN INC.,
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`Defendant and Counterclaim Plaintiff.
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`C.A. No. 18-924-CFC
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`Original Version Filed: March 13, 2020
`Public Version Filed; March 20, 2020
`
`DECLARATION OF
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`
`
`1
`
`
`
`Case 1:18-cv-00924-CFC-SRF Document 540 Filed 03/20/20 Page 2 of 3 PageID #:
`34920
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`I,
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`, declare as follows:
`
`1.
`
`I am employed by Epiq Systems, Inc. (“Epiq”) as a Project Director. I
`
`am familiar with the facts set forth herein, and if called as a witness, I could and
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`would testify competently to those facts under oath.
`
`2.
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`Early on February 29, 2020, Epiq experienced a cyber incident. As part
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`of Epiq’s comprehensive response plan, it immediately took its systems offline
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`globally.
`
`
`
`
`
`
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`3.
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`No documents, metadata, or Amgen work-product (including back-up
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`copies) can be accessed or exported by Epiq, Amgen, or outside counsel until the
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`discovery database is back online and it has been certified by Epiq and Amgen’s in-
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`house IT security department. Which documents, metadata or work product will be
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`then available (and over what time frame) depends on the nature of the damage
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`caused by the attack, the condition of backups available, and the time needed to
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`reconstitute what can be reconstituted.
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`4.
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`Epiq is working to resolve this issue as quickly as possible.
`
`
`
`2
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`
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`Case 1:18-cv-00924-CFC-SRF Document 540 Filed 03/20/20 Page 3 of 3 PageID #:
`34921
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`
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`5.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`
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`Dated: March 12, 2020
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`/s/
`
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`
`
`Epiq Systems, Inc.
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`3
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`
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