`
`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
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`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:
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`1.
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`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
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`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.
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`2.
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`Attached as Exhibit 1 to this Declaration is a true and accurate copy of a letter from
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`Natasha E. Daughtrey to Emily R. Gabranski dated February 12, 2021.
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`3.
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`Attached as Exhibit 2 to this Declaration is a true and accurate copy of a letter from
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`Emily R. Gabranski to Natasha E. Daughtrey dated January 28, 2021.
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`4.
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`Attached as Exhibit 3 to this Declaration is a true and accurate copy of an e-mail
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`from Emily R. Gabranski to counsel for Teva dated February 25, 2021, 4:34 P.M.
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`1
`
`
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`Case 1:18-cv-12029-ADB Document 108 Filed 03/10/21 Page 2 of 3
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`5.
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`Attached as Exhibit 4 to this Declaration is a true and accurate copy of an email
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`from Daniel F. Roland to counsel for Teva dated March 1, 2021, 8:45 A.M.
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`6.
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`Attached as Exhibit 5 to this Declaration is a true and accurate copy of a letter from
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`Amana Abdulwakeel to Natasha E. Daughtrey dated March 8, 2021. Information designated
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`CONFIDENTIAL or HIGHLY CONFIDENTIAL pursuant to the parties’ Stipulated Protective
`
`Order (ECF No. 58) has been redacted.
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`7.
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`Attached as Exhibit 6 to this Declaration is a true and accurate copy of a letter from
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`Amana Abdulwakeel to Elaine Herrmann Blais dated September 17, 2020.
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`8.
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`Attached as Exhibit 7 to this Declaration is a true and accurate copy of a letter from
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`Amana Abdulwakeel to Natasha E. Daughtrey dated November 23, 2020. Information designated
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`CONFIDENTIAL or HIGHLY CONFIDENTIAL pursuant to the parties’ Stipulated Protective
`
`Order (ECF No. 58) has been redacted.
`
`9.
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`Attached as Exhibit 8 to this Declaration is a true and accurate copy of a letter from
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`Amana Abdulwakeel to Natasha E. Daughtrey dated December 11, 2020.
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`10.
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`Attached as Exhibit 9 to this Declaration is a true and accurate copy of a letter from
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`Amana Abdulwakeel to Natasha E. Daughtrey dated December 18, 2020.
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`11.
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`Attached as Exhibit 10 to this Declaration is a true and accurate copy of a letter
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`from Amana Abdulwakeel to Natasha E. Daughtrey dated December 23, 2020.
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`12.
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`Attached as Exhibit 11 to this Declaration is a true and accurate copy of a letter
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`from Amana Abdulwakeel to Natasha E. Daughtrey dated January 6, 2021.
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`13.
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`Attached as Exhibit 12 to this Declaration is a true and accurate copy of a letter
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`from Emily R. Gabranski to Natasha E. Daughtrey dated January 20, 2021.
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`2
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`
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`Case 1:18-cv-12029-ADB Document 108 Filed 03/10/21 Page 3 of 3
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`14.
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`Attached as Exhibit 13 to this Declaration is a true and accurate copy of a letter
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`from Amana Abdulwakeel to Natasha E. Daughtrey dated January 25, 2021.
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`15.
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`Attached as Exhibit 14 to this Declaration is a true and accurate copy of a letter
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`from Amana Abdulwakeel to Natasha E. Daughtrey dated February 16, 2021.
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`16.
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`Attached as Exhibit 15 to this Declaration is a true and accurate copy of a letter
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`from Elaine Herrmann Blais to Emily R. Gabranski dated March 4, 2021.
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`17.
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`Attached as Exhibit 16 to this Declaration is a true and accurate copy of J. Michael
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`Jakes et al., Federal Circuit Basics: Managing the Substance and Procedure of a Patent Appeal,
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`IP LITIGATOR, January/February 2020 (reprinted with permission from Wolters Kluwer on the
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`website of Finnegan, Henderson, Farabow, Garrett & Dunner, LLP).
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`I declare under the penalty of perjury that the foregoing is true and correct.
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`Executed on this 10th day of March, 2021.
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` /s/ Emily R. Gabranski
`Emily R. Gabranski
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`3
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`