Free Declaration in Support - District Court of California - California


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Date: January 28, 2008
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State: California
Category: District Court of California
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Case 3:07-cv-02845-WHA

Document 108-4

Filed 01/28/2008

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Case 3:07-cv-02845-WHA

Document 108-4

Filed 01/28/2008

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John R. Labbé (312) 423-3453 [email protected]

January 22, 2008 Via Electronic Mail and U.S. Mail Bryan Wilson Morrison & Foerster LLP 755 Page Mill Road Palo Alto, CA 94304-1018 [email protected] Re: Applera Corporation ­ Applied Biosystems Group v. Illumina, Inc., et al., Case No. 07-CV-02845 WHA

Bryan: This is in response to your letters of January 16 and January 18. Illumina intends to take the depositions of Mike Hunkapillar and Paul Grossman. AB's Amended Initial Disclosure Statement indicates that Morrison & Foerster is representing these two former AB employees. Please confirm that you will accept service of deposition subpoenas and/or subpoenas duces tecum on behalf of these two witnesses as well as any other witnesses identified as "c/o Morrison & Foerster" in AB's Amended Initial Disclosure Statement. We are generally available to take these two depositions on any two consecutive days in February. Please provide available dates for these two witnesses. Illumina intends to take the deposition of Vincent Powers. We are considering your proposal that AB and Illumina split the fees for an attorney to represent Mr. Powers in connection with his deposition. We will follow-up with you about this matter shortly. Illumina also intends to take at least one Fed. R. Civ. P. 30(b)(6) deposition of AB. We will provide you with a draft 30(b)(6) deposition notice so that you can identify the appropriate witness or witnesses and schedule a date for that deposition.

Case 3:07-cv-02845-WHA

Document 108-4

Filed 01/28/2008

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Bryan Wilson January 22, 2008 Page 2 Finally, as you know, AB disclosed a lengthy list of witnesses in its Amended Initial Disclosure Statement. Please identify which of these witnesses AB reasonably expects to call to testify at trial, and we can then work to schedule the depositions of those witnesses. Sincerely,

John R. Labbé

cc: Kevin Flowers