Free Redacted Document - District Court of Delaware - Delaware

Case 1:05-cv-00340-SLR Document 112 Filed 05/15/2006 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
)
IN RE: TRICOR DIRECT PURCHASER )
ANTITRUST LITIGATION ) C.A. No. 05-340 (KAJ)
)

) Hon. Kent Jordan, U.S.D.J.
THIS DOCUMENT RELATES TO: )
ALL ACTIONS ) HIGHLY CONFIDENTIAL -—
C .A. No. 05-340 (Louisiana Wholesale) ) FILED UNDER SEAL
C.A. No. 05-351 (Rochester Drug) ) PURSUANT TO COURT ORDER
C.A. No. 05-358 (Meijer, Inc., et al.) )

DECLARATION OF JEFFREY S. GODDESS, ESQ.
(PUBLIC VERSION)
JEFFREY S. GODDESS, ESQ. does hereby declare the following:
1. I am a partner in the firm of Rosenthal, Monhait & Goddess, P.A., counsel for
plaintiffs in this matter. I submit this Declaration in conjunction with Direct Purchaser Class
Plaintiffs’ Opening Brief In Support of Their Motion for Class Certification.
2 Attached hereto as Exhibit "A" is a true and correct copy of the transcript of the
Deposition of Joseph Edward Fiske, Abbott Laboratories’ Rule 30(b)(6) designee, dated April 21,
2006 (Fiske Deposition).
3. Attached hereto as Exhibit "B" is a true and correct copy ofthe Declaration of Jeffrey
J. Leitzinger, Ph.D., dated May 8, 2006, with exhibits.
4. Attached hereto as Exhibit "C" is a true and correct copy of a document stamped
Tricor0260-66, bearing the date September 26, 1996.
5. Attached hereto as Exhibit "D" is a true and correct copy of a document stamped
Abbott_Tricor01243-46, which was marked as Exhibit 12 during the Fiske Deposition.

Case 1 :05-cv-00340-SLR Document 112 Filed 05/15/2006 Page 2 of 2
6. Attached hereto as Exhibit "E" is a true and correct copy ofthe telephonic hearing
transcript of March 3, 2006, before this Court.
7. Attached hereto as Exhibit "F" is a true and correct copy of the resume of the firm
Garwin Gerstein & Fisher, LLP.
8. Attached hereto as Exhibit "G" is a true and correct copy ofthe resume ofthe firm
Berger & Montague, P.C. -
9. Attached hereto as Exhibit "H" is a true and correct copy of the resume of the firm
Odom & Des Roches, LLP.
10. Attached hereto as Exhibit "I" is a true and correct copy of the resume of the firm
Percy, Smith & Foote, LLP.
ll. Attached hereto as Exhibit "J" is a true and correct copy of the resume of the firm
Cohen, Milstein, Hausfeld & Toll, PLLC.
12. Attached hereto as Exhibit "K" is a true and correct copy of the firm Rosenthal,
Monhait & Goddess, P.A.
1. Attached hereto as Exhibit "L" is a true and correct copy of a document stamped
Abbott_Tricor093 5-52, entitled ". REDACTED ," which was marked as Exhibit 17
at the Fiske Deposition.
I am signing this Declaration under penalty of perjury.
}
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