`Case 1:18-cv-12029-ADB Document 202 Filed 10/22/21 Page 1 of 4
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF MASSACHUSETTS
`
`TEVA PHARMACEUTICALS
`INTERNATIONAL GMBHand
`TEVA PHARMACEUTICALS
`USA,INC.,
`
`Plaintiffs,
`
`Vv.
`
`Civil Action No.
`1:18-cv-12029-ADB
`
`Defendant.
`
`ELI LILLY AND COMPANY,
`
`DECLARATION OF DR. GEOFFREY HALE IN SUPPORT OF PLAINTIFFS TEVA
`PHARMACEUTICALS INTERNATIONAL GMBH
`AND TEVA PHARMACEUTICALSUSA, INC.’S OPPOSITION TO
`MOTION TO EXCLUDE DR. GEOFFREY HALE AS AN EXPERT
`
`I, Dr. Geoffrey Hale, declare as follows:
`
`1.
`
`I am an expert in the field of antibody development, including the humanization
`
`of antibodies. My current posts include serving as a freelance scientist and consultant, the CEO
`
`of mAbsolve, and the managing director of Bioarchitech. All of my work relates to some extent
`
`to antibody development, including the humanization of antibodies.
`
`2.
`
`Over the last 10 years as a freelance consultant, I have consulted on over 60
`
`projects for approximately 45 different companies, most of which are pharmaceutical companies.
`
`All of this work related to antibody development, including the humanization of antibodies. This
`
`work has been my main source of earned income for the past 10 years.
`
`I have never been
`
`engaged by Lilly or any other client on terms which indefinitely limit my ability to act as a
`
`consultant for other companies, including in the area of humanization of antibodies.
`
`
`
`Case 1:18-cv-12029-ADB Document 202 Filed 10/22/21 Page 2 of 4
`
`
`
`3.
`
`I understand that the defendant, Eli Lilly and Company (“Lilly”), has objected to
`
`me serving as an expert for Teva in this case based on
`
`
`
`asserted that
`
`. I understand Lilly has
`
` and that the
`
`confidential information related to the issues in this case because they also pertained to
`
`. I also understand Lilly has asserted that
`
`
`
`. I also understand Lilly has asserted that
`
`a company,
`
`, was also involved in
`
`
`
`4.
`
`While I don’t have any reason to dispute that
`
`have no recollection of the content of
`
`. As far as I can recall,
`
`
`
`
`
`
`
`
`
`, I
`
`
`
`. I do not have any such documents in my
`
`possession.
`
`5.
`
`Regarding the work done by
`
`, I
`
`have no specific recollection of what, if anything,
`
`
`
` Indeed, I
`
`would not have typically been involved in work that the company did. Instead, what would have
`
`typically occurred if I was engaged to work on a project where
`
` was also
`
`engaged would be that I would be paid separately as a consultant to provide input on
`
`
`
`. Those experiments would then be conducted by
`
` without
`
`further input or supervision from me (my role with
`
` at the relevant times was
`
`as a
`
` and I did not have any executive responsibilities).
`
`
`
`2
`
`
`
`Case 1:18-cv-12029-ADB Document 202 Filed 10/22/21 Page 3 of 4
`Case 1:18-cv-12029-ADB Document 202 Filed 10/22/21 Page 3 of 4
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`I declare, under penalty of perjury, that the foregoing is true and correct to the best of my
`
`knowledge, andthat I executed this declaration in Oxford, United Kingdom on this 18" day of
`
`October, 2021.
`
`¥
`
`Respectfully Submitted, Aw
`
`Dr. Geoffrey Hale
`
`Lad
`
`
`
`Case 1:18-cv-12029-ADB Document 202 Filed 10/22/21 Page 4 of 4
`
`CERTIFICATE OF SERVICE
`
`I, Elaine Herrmann Blais, hereby certify that on October 22, 2021, a copy of the
`
`foregoing document was served on the following persons via email:
`
`Andrea L. Martin
`BURNS & LEVINSON LLP
`125 High Street
`Boston, MA 02110-1624
`(617) 345-3000
`amartin@burnslev.com
`
`Emily R. Gabranski
`Marta Garcia Daneshvar
`Lulu Wang
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`2 Seaport Lane
`Boston, MA 02210-2001
`Emily.Gabranski@finnegan.com
`Marta.Garcia@finnegan.com
`Lulu.Wang@finnegan.com
`
`Mark J. Stewart
`Sanjay M. Jivraj
`ELI LILLY AND COMPANY
`Lilly Corporate Center
`Indianapolis, IN 46285
`stewart_mark@lilly.com
`sjivraj@lilly.com
`
`Attorneys for Defendant
`
`Charles E. Lipsey
`Ryan P. O’Quinn
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`1875 Explorer Street
`Suite 800
`Reston, VA 20190-6023
`Charles.Lipsey@finnegan.com
`Ryan.o’quinn@finnegan.com
`
`William B. Raich
`Denise Main
`Danielle A. Duszczyszyn
`Pier D. DeRoo
`Daniel F. Roland
`Matthew J. Luneack
`Yoonjin Lee
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`901 New York Avenue, NW
`Washington, DC 20001-4413
`William.Raich@finnegan.com
`Denise.Main@finnegan.com
`Danielle.Duszczyszyn@finnegan.com
`Pier.Deroo@finnegan.com
`Daniel.Roland@finnegan.com
`Matthew.Luneack@finnegan.com
`Yoonjin.Lee@finnegan.com
`
`/s/ Elaine Herrmann Blais
`Elaine Herrmann Blais (BBO# 656142)
`GOODWIN PROCTER LLP
`100 Northern Avenue
`Boston, MA 02210
`(617) 570-1000
`eblais@goodwinlaw.com
`
`21
`
`
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