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`GENENTECH, INC. and CITY OF HOPE,
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`v.
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`AMGEN, INC.,
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`Plaintiffs,
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`Defendant.
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`C.A. No. 18-924-CFC
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`SUPPLEMENTAL DECLARATION OF NORA Q.E. PASSAMANECK IN SUPPORT OF
`PLAINTIFFS’ EMERGENCY MOTION FOR A TEMPORARY RESTRAINING ORDER
`AND A PRELIMINARY INJUNCTION
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`I, Nora Q.E. Passamaneck, declare and state as follows:
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`1.
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`I am an attorney at Wilmer Cutler Pickering Hale and Dorr LLP, counsel for
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`Genentech, Inc. (“Genentech”) in Case No. 18-cv-00924-GMS (D. Del.). I am familiar with the
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`facts set forth herein, and if called as a witness, I could and would testify competently to those
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`facts under oath.
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`2.
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`Attached hereto as Exhibit 230 is a true and correct copy of an excerpted version
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`of United States Patent No. 6,627,196.
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`3.
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`Attached hereto as Exhibit 231 is a true and correct copy of an excerpted version
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`of a book titled, “Clinical Pharmacokinetics, Concepts and Applications, third ed.,” by Malcolm
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`Rowland & Thomas Tozer, which was submitted in IPR Exhibit No. IPR2017-01139 as
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`Genentech Exhibit 2007.
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`4.
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`Attached hereto as Exhibit 232 is a true and correct copy of an excerpted version
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`of a book titled, “Pharmacokinetic and Pharmacodynamic Data Analysis: Concepts and
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`1
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`PUBLIC VERSION FILED: July 25, 2019
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`Case 1:18-cv-00924-CFC Document 328 Filed 07/25/19 Page 2 of 3 PageID #: 25735
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`Applications,” by Johan Gabrielsson and Daniel Weiner, which was submitted in IPR Exhibit
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`No. IPR2017-01139 as Genentech Exhibit 2006.
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`5.
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`Attached hereto as Exhibit 233 is a true and correct copy of a June 18, 2019 email
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`from counsel for Amgen, Orion Armon, to counsel for Genentech titled “Genentech, Inc et al. v.
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`Amgen, Inc. (18-924-CFC): Deposition scheduling change.”
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`6.
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`Attached hereto as Exhibit 234 is a true and correct copy of an excerpted version
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`of the
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`Confidential.
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`. This exhibit is marked
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`7.
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`Attached hereto as Exhibit 235 is a true and correct copy of an excerpted version
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`of the
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`Confidential.
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`. This exhibit is marked
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`8.
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`Attached hereto as Exhibit 236 is a true and correct copy of an excerpted version
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`of the
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`Confidential.
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`. This exhibit is marked
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`9.
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` Attached hereto as Exhibit 237 is a true and correct copy of an excerpted version
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`of the
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`Confidential.
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`. This exhibit is marked
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`10.
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`Attached hereto as Exhibit 238 is a true and correct copy of an excerpted version
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`of the Sharon Baughman Deposition Transcript, dated May 9, 2019. This exhibit is marked
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`Confidential.
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`11.
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`Attached hereto as Exhibit 239 is a true and correct copy of an excerpted version
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`of the Steven Shak Deposition Transcript, dated May 11, 2019. This exhibit is marked
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`Confidential.
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`2
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`Case 1:18-cv-00924-CFC Document 328 Filed 07/25/19 Page 3 of 3 PageID #: 25736
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`12.
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`Attached hereto as Exhibit 240 is a true and correct copy of an excerpted version
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`of the Larry Norton Deposition Transcript, dated June 17, 2019. This exhibit is marked
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`Confidential.
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`13.
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`Attached hereto as Exhibit 241 is a true and correct copy of an excerpted version
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`of the Christy Oliger Deposition Transcript, dated June 14, 2019. This exhibit is marked
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`Confidential.
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`14.
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`Attached hereto as Exhibit 242 is a true and correct copy of an excerpted version
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`of the Jennifer Glasgow Deposition Transcript, dated June 4, 2019. This exhibit is marked
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`Confidential.
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`15.
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`Attached hereto as Exhibit 243 is a true and correct copy of an excerpted version
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`of Amgen’s Opening Brief in Support of Motion for Permanent Injunctive Relief, in Amgen Inc.
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`et al. v. Sanofi et al., No. 14-cv-1317-SLR (D. Del. April 27, 2016), ECF No. 340.
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`16.
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`Attached hereto as Exhibit 244 is a true and correct copy of a document titled,
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`“
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`is marked Confidential.
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`,” bearing Bates number GNE-HER_002952248. This exhibit
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`I declare under penalty of perjury that the foregoing is true and correct to the best of my
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`knowledge.
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`EXECUTED this 16th day of July, 2019.
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`By: /s/ Nora Q. E. Passamaneck
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`Nora Q. E. Passamaneck
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`3
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