Case: 1:16-cv-00651 Document #: 114-6 Filed: 06/25/18 Page 1 of 3 PageID #:3399
`Case: 1:16—cv—00651 Document #: 114-6 Filed: 06/25/18 Page 1 of 3 PageID #:3399
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`SECTION IV-A
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`SECTION IV-A
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`Case: 1:16-cv-00651 Document #: 114-6 Filed: 06/25/18 Page 2 of 3 PageID #:3400
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`Hospira’s Witness List
`Hospira intends to call the following witnesses to testify at trial. The “Will Call” list
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`represents a good faith statement of those witnesses Hospira presently intends to call live. The
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`“May Call” list represents a good faith statement of those witnesses that Hospira may call live or
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`by deposition designation.
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`Hospira reserves the right to call any additional witnesses necessitated by any of the
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`Court’s pretrial or trial rulings. Hospira also reserves the right to call, either live or by deposition:
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`(a) additional witnesses to provide foundational testimony should any party contest the authenticity
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`or admissibility of any material proffered at trial; (b) substitute witnesses for any identified witness
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`whose employment or other relationship with Hospira changes such that he or she is no longer
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`able, available or willing to testify on Hospira’s behalf at trial; (c) any witnesses identified by
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`Fresenius Kabi; (d) any witnesses required to rebut Fresenius Kabi’s case; or (e) additional
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`witnesses to respond to issues raised after the submission of this list.
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`I.
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`Will Call – Witnesses Hospira Expects to Call Live at Trial
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`1.
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`2.
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`3.
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`4.
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`5.
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`6.
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`Priyanka Roychowdhury (co-inventor of Patents-in-Suit) (only available July 16)
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`Andrew Carter (expert witness in the field of economics who will testify regarding
`secondary considerations of non-obviousness)
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`Robert Linhardt (expert witness in the field of pharmaceutical formulation and
`development who will testify regarding validity)
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`Stephan Ogenstad (expert witness in the field of biostatistics who will testify
`regarding validity)
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`Michael Ramsay (expert witness in the field of clinical sedation and anesthesiology
`who will testify regarding validity)
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`R. Christopher Seaton (expert witness in the field of pharmaceutical commercial
`transactions who will testify regarding validity, specifically the transactions that are
`the subject of Fresenius Kabi’s on-sale bar argument, including the business
`community’s treatment of these transactions)
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`1
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`Case: 1:16-cv-00651 Document #: 114-6 Filed: 06/25/18 Page 3 of 3 PageID #:3401
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`II. May Call – Witnesses Hospira May Call Live Or By Deposition Designation
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`7.
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`1.
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`2.
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`3.
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`4.
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`5.
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`6.
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`7.
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`James J. White (expert in the field of the Uniform Commercial Code who will
`testify regarding validity, specifically the transactions that are the subject of
`Fresenius Kabi’s on-sale bar argument, including the UCC’s treatment of these
`transactions)
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`Robert Cedergren (live) (co-inventor of patents-in-suit)
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`David Engels (live) (U.S. Sterile Injectables Portfolio Lead, Pfizer, Inc., who will
`testify regarding the commercial performance of Precedex Premix)
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`Rao Tata-Venkata (live) (Hospira research scientist involved in development of
`Hospira’s ready-to-use dexmedetomidine product)
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`Lisa Zboril (live) (Hospira regulatory affairs team member for Hospira’s
`dexmedetomidine products)
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`Eric Sheinin (live) (expert witness in the field of FDA regulatory process who will
`testify regarding validity, specifically the nature of the Investigational New Drug
`application that is a subject of Fresenius Kabi’s on-sale bar argument)
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`Basma Ibrahim (deposition designation) (Fresenius Kabi principal scientist)
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`Shweta Mowli (deposition designation) (Fresenius Kabi project manager)
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`2
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