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`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF NEW YORK
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`Civil Action No. 14-CV-2758 (PAC)
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`Kowa Company, Ltd. et al.,
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`Plaintiffs,
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`v.
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`Amneal Pharmaceuticals LLC,
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`Defendant.
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`DECLARATION OF STEVEN A. MADDOX IN SUPPORT OF MOTION IN LIMINE OF
`DEFENDANT AMNEAL PHARAMCEUTICALS, LLC TO EXCLUDE EXPERT
`TESTIMONY FOR REFUSAL TO PROVIDE DEPOSITION OF THE EXPERT
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`I, Steven A. Maddox, declare under oath as follows:
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`1.
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`I am a partner with the law firm Maddox Edwards PLLC, counsel for Defendant Amneal
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`Pharmaceuticals, LLC (“Amneal”) in connection with Case No. 1:14-cv-02758-PAC.
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`2.
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`I make this declaration in support of the Motion in Limine of Defendant Amneal
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`Pharmaceuticals, LLC to Exclude Expert Testimony for Refusal to Provide Deposition of the
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`Expert.
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`3.
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`To the best of my knowledge and belief, attached hereto as Exhibit 1 is a true and correct
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`copy of an email chain between Amneal’s counsel and Plaintiffs’ counsel, including a
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`November 9, 2016 email from Amneal’s counsel to Plaintiffs’ counsel, a November 10, 2016 email
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`from Plaintiffs’ counsel to Amneal’s counsel, and November 26, 2016 Email from Amneal’s
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`counsel to Plaintiffs’ counsel [redacted for confidentiality].
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`4.
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`To the best of my knowledge and belief, attached hereto as Exhibit 2 is a true and correct
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`copy of a December 15, 2016 email from Plaintiffs’ counsel to Amneal’s counsel [redacted for
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`confidentiality].
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`Case 1:14-cv-02758-PAC Document 104-1 Filed 12/16/16 Page 2 of 2
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`I declare under penalty of perjury that the foregoing is true and correct to the best of my
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`knowledge.
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`Dated: December 16, 2016
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`/s/ Steven A. Maddox
`Steven A. Maddox
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`2
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