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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`GENENTECH, INC. and CITY OF HOPE,
`Plaintiffs,
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`v.
`AMGEN INC.,
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`
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`Defendant.
`
`C.A. No. 18-00924-CFC
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`MOTION TO COMPEL
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`Defendant Amgen Inc. respectfully requests that the Court compel Plaintiffs Genentech,
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`Inc. and City of Hope to produce certain licensing and settlement agreements and related materials
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`and Rule 30(b)(6) deposition testimony relating thereto. The grounds for this motion are set forth
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`in the accompanying discovery dispute letter, and the specific relief is set forth in the Proposed
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`Order, filed herewith.
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`Case 1:18-cv-00924-CFC Document 191 Filed 05/13/19 Page 2 of 2 PageID #: 17422
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`SMITH, KATZENSTEIN & JENKINS, LLP
`
`
`/s/ Neal C. Belgam
`Neal C. Belgam (No. 2721)
`Eve H. Ormerod (No. 5369)
`1000 West Street, Suite 1501
`Wilmington, DE 19801
`P (302) 652-8400
`nbelgam@skjlaw.com
`eormerod@skjlaw.com
`
`Attorneys for Defendant Amgen Inc.
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`Dated: May 13, 2019
`
`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
`
`Orion Armon
`Cooley LLP
`380 Interlocken Crescent, Suite 900
`Broomfield, CO 80021-8023
`P (720) 566-4000
`oarmon@cooley.com
`
`Eamonn Gardner
`Cooley LLP
`4401 Eastgate Mall
`San Diego, CA 92121-1909
`P (858) 550-6000
`egardner@cooley.com
`
`Nancy Gettel
`Thomas Lavery, IV
`Amgen Inc.
`One Amgen Center Drive
`Thousand Oaks, CA 91320-1799
`P (805) 447-1000
`ngettel@amgen.com
`tlavery@amgen.com
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