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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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`v.
`AMGEN INC.,
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`C.A. No. 18-924-CFC
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`Defendant.
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`AMGEN INC.’S MOTION FOR PROTECTIVE ORDER AGAINST UNTIMELY
`SUBPOENAS
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`Amgen Inc. respectfully requests that the Court issue a protective order that (1) voids the
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`subpoenas recently issued by Genentech, Inc. (“Genentech”) and mandates their withdrawal; and
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`(2) excludes from evidence at the December 2019 trial any information that Genentech obtained
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`from third-parties who received the subpoenas. The grounds for this motion are set forth in the
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`accompanying discovery dispute letter, and the specific relief is set forth in the Proposed Order,
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`filed herewith.
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`Case 1:18-cv-00924-CFC Document 413 Filed 10/13/19 Page 2 of 2 PageID #: 31201
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`Dated: October 13, 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
`Lois Kwasigroch
`Brian Kao
`Amgen Inc.
`One Amgen Center Drive
`Thousand Oaks, CA 91320-1799
`P (805) 447-1000
`ngettel@amgen.com
`loisk@amgen.com
`bkao@amgen.com
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`Christopher B. Mead
`London & Mead
`1225 19th Street, N.W., Ste 230
`Washington, D.C. 20036
`P (202) 331-3334
`cmead@londonandmead.com
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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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