`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MASSACHUSETTS
`
`TEVA PHARMACEUTICALS
`INTERNATIONAL GMBH and
`TEVA PHARMACEUTICALS
`USA, INC.,
`
`Plaintiffs,
`
`v.
`
`ELI LILLY AND COMPANY,
`
`Defendant.
`
`Civil Action No.
`1:18-cv-12029-ADB
`
`DECLARATION OF EMILY R. GABRANSKI IN SUPPORT OF
`DEFENDANT’S MOTION TO EXTEND FACT DISCOVERY BY NINETY DAYS
`
`I, Emily R. Gabranski, declare as follows:
`
`1.
`
`I am an attorney at the law firm of Finnegan, Henderson, Farabow, Garrett &
`
`Dunner, LLP, counsel for Eli Lilly and Company in this matter. I am licensed to practice in the
`
`Commonwealth of Massachusetts and admitted to practice before the United States District Court
`
`for the District of Massachusetts. I have personal knowledge of the matters set forth herein.
`
`2.
`
`Attached as Exhibit 1 to this Declaration is a true and accurate copy of a letter from
`
`Natasha E. Daughtrey to Emily R. Gabranski dated February 12, 2021.
`
`3.
`
`Attached as Exhibit 2 to this Declaration is a true and accurate copy of a letter from
`
`Emily R. Gabranski to Natasha E. Daughtrey dated January 28, 2021.
`
`4.
`
`Attached as Exhibit 3 to this Declaration is a true and accurate copy of an e-mail
`
`from Emily R. Gabranski to counsel for Teva dated February 25, 2021, 4:34 P.M.
`
`1
`
`
`
`Case 1:18-cv-12029-ADB Document 108 Filed 03/10/21 Page 2 of 3
`
`5.
`
`Attached as Exhibit 4 to this Declaration is a true and accurate copy of an email
`
`from Daniel F. Roland to counsel for Teva dated March 1, 2021, 8:45 A.M.
`
`6.
`
`Attached as Exhibit 5 to this Declaration is a true and accurate copy of a letter from
`
`Amana Abdulwakeel to Natasha E. Daughtrey dated March 8, 2021. Information designated
`
`CONFIDENTIAL or HIGHLY CONFIDENTIAL pursuant to the parties’ Stipulated Protective
`
`Order (ECF No. 58) has been redacted.
`
`7.
`
`Attached as Exhibit 6 to this Declaration is a true and accurate copy of a letter from
`
`Amana Abdulwakeel to Elaine Herrmann Blais dated September 17, 2020.
`
`8.
`
`Attached as Exhibit 7 to this Declaration is a true and accurate copy of a letter from
`
`Amana Abdulwakeel to Natasha E. Daughtrey dated November 23, 2020. Information designated
`
`CONFIDENTIAL or HIGHLY CONFIDENTIAL pursuant to the parties’ Stipulated Protective
`
`Order (ECF No. 58) has been redacted.
`
`9.
`
`Attached as Exhibit 8 to this Declaration is a true and accurate copy of a letter from
`
`Amana Abdulwakeel to Natasha E. Daughtrey dated December 11, 2020.
`
`10.
`
`Attached as Exhibit 9 to this Declaration is a true and accurate copy of a letter from
`
`Amana Abdulwakeel to Natasha E. Daughtrey dated December 18, 2020.
`
`11.
`
`Attached as Exhibit 10 to this Declaration is a true and accurate copy of a letter
`
`from Amana Abdulwakeel to Natasha E. Daughtrey dated December 23, 2020.
`
`12.
`
`Attached as Exhibit 11 to this Declaration is a true and accurate copy of a letter
`
`from Amana Abdulwakeel to Natasha E. Daughtrey dated January 6, 2021.
`
`13.
`
`Attached as Exhibit 12 to this Declaration is a true and accurate copy of a letter
`
`from Emily R. Gabranski to Natasha E. Daughtrey dated January 20, 2021.
`
`2
`
`
`
`Case 1:18-cv-12029-ADB Document 108 Filed 03/10/21 Page 3 of 3
`
`14.
`
`Attached as Exhibit 13 to this Declaration is a true and accurate copy of a letter
`
`from Amana Abdulwakeel to Natasha E. Daughtrey dated January 25, 2021.
`
`15.
`
`Attached as Exhibit 14 to this Declaration is a true and accurate copy of a letter
`
`from Amana Abdulwakeel to Natasha E. Daughtrey dated February 16, 2021.
`
`16.
`
`Attached as Exhibit 15 to this Declaration is a true and accurate copy of a letter
`
`from Elaine Herrmann Blais to Emily R. Gabranski dated March 4, 2021.
`
`17.
`
`Attached as Exhibit 16 to this Declaration is a true and accurate copy of J. Michael
`
`Jakes et al., Federal Circuit Basics: Managing the Substance and Procedure of a Patent Appeal,
`
`IP LITIGATOR, January/February 2020 (reprinted with permission from Wolters Kluwer on the
`
`website of Finnegan, Henderson, Farabow, Garrett & Dunner, LLP).
`
`I declare under the penalty of perjury that the foregoing is true and correct.
`
`Executed on this 10th day of March, 2021.
`
` /s/ Emily R. Gabranski
`Emily R. Gabranski
`
`3
`
`
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