`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Louden, William <William.Louden@apks.com>
`Saturday, May 06, 2017 2:56 PM
`Cordrey, Gregory; Wu, Wallace; Sklenar, Jennifer
`Nyarady, Catherine; Egan, Brian P.
`RE: IPR2017-00060 [JMBM-OC.FID560329]
`
`Greg,
`
`
`BSC agrees to take the deposition of Dr. Buller on June 15 at the offices of Morris Nichols in Wilmington, DE. This
`examination will only be in regards to Dr. Buller’s testimony submitted in IPR2017‐00060. Examining Dr. Buller on his
`IPR2017‐01293 testimony at the same deposition is contrary to the rules, particularly as the second ‘608 proceeding has
`not been instituted, and it would prejudice BSC to be forced to take a single deposition on grounds from different
`petitions on the same date and without the benefit of an institution decision in the second proceeding. If IPR2017‐
`01293 is instituted, we will schedule a second deposition of Dr. Buller in accordance with the PTO’s rules and guidelines.
`
`
`Moreover, we think it is best for the party taking the cross‐examination testimony to make arrangements for a court
`reporter. Accordingly, BSC will make arrangements for a court reporter for Dr. Buller’s deposition. Please let me know if
`you have any questions.
`
`
`Best,
`
`
`William
`
`
`
`
`William Z. Louden | Associate
`Arnold & Porter Kaye Scholer LLP | 601 Massachusetts Ave., NW, Washington DC 20001‐3743
`(o): 202.942.6909 | (m): 215.262.1810
`william.louden@apks.com | www.apks.com
`
`From: Cordrey, Gregory [mailto:GXC@JMBM.com]
`Sent: Monday, May 01, 2017 5:02 PM
`To: Louden, William; Wu, Wallace; Sklenar, Jennifer
`Cc: Nyarady, Catherine; 'began@MNAT.com'
`Subject: RE: IPR2017-00060 [JMBM-OC.FID560329]
`
`Counsel,
`
`Dr. Buller is not available during the weeks of 5/29 and 6/5. However, Dr. Buller is available on June 15th (Thursday) for
`his deposition at the offices of Morris Nichols in Wilmington, DE. Also, at that time, Dr. Buller also will be prepared to be
`examined on his declaration provided in support of the Edwards’ second IPR petition on the ’608 Patent.
`
`We look forward to hearing from you.
`
`Regards,
`Greg
`
`
`
`1
`
`Exhibit 1157
`
`
`
`Gregory S. Cordrey | Partner
`Jeffer Mangels Butler & Mitchell LLP | JMBM
`3 Park Plaza, Suite 1100, Irvine, CA 92614
`D: (949) 623‐7236 | F: (949) 623‐7202 | E: GCordrey@JMBM.com
`VCARD | BIO | BLOG | LINKEDIN
`
`
`This e‐mail message and any attachments are confidential and may be attorney‐client privileged. Dissemination, distribution or copying of this message or
`attachments without proper authorization is strictly prohibited. If you are not the intended recipient, please notify JMBM immediately by telephone or by e‐mail, and
`permanently delete the original, and destroy all copies, of this message and all attachments. For further information, please visit JMBM.com.
`
`
`
`From: Louden, William [mailto:William.Louden@apks.com]
`Sent: Tuesday, April 25, 2017 8:53 AM
`To: Cordrey, Gregory; 'began@MNAT.com'; Nyarady, Catherine
`Cc: Sklenar, Jennifer; Wu, Wallace
`Subject: IPR2017-00060
`
`Counsel,
`
`Boston Scientific intends to take the deposition of Dr. Buller. Please let us know when he is available during the weeks
`of 5/29 and 6/5.
`
`Best,
`
`William
`
`
`
`
`William Z. Louden | Associate
`Arnold & Porter Kaye Scholer LLP | 601 Massachusetts Ave., NW, Washington DC 20001‐3743
`(o): 202.942.6909 | (m): 215.262.1810
`william.louden@apks.com | www.apks.com
`
`
`
`This communication may contain information that is legally privileged, confidential or exempt from disclosure. If you are not the intended recipient, please note that
`any dissemination, distribution, or copying of this communication is strictly prohibited. Anyone who receives this message in error should notify the sender
`immediately by telephone or by return e-mail and delete it from his or her computer.
`_____________________________
`For more information about Arnold & Porter Kaye Scholer LLP, click here:
`http://www.apks.com
`
`
`This communication may contain information that is legally privileged, confidential or exempt from disclosure. If you are not the intended recipient, please note that
`any dissemination, distribution, or copying of this communication is strictly prohibited. Anyone who receives this message in error should notify the sender
`immediately by telephone or by return e-mail and delete it from his or her computer.
`_____________________________
`For more information about Arnold & Porter Kaye Scholer LLP, click here:
`http://www.apks.com
`
`2
`
`Exhibit 1157
`
`