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EXHIBIT U

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
MCKESSON INFORMATION SOLUTIONS

LLC,
Plaintift
v.

)

THE TRIZEUO GROUP, INC.,
Defendant.

) ) ) ) ) ) ) ) )

C.A. No. 04-1258 (SLR)

DEFENDANT THE TRIZETTO GROUP, INC.'S

FIRST SET OF INTERROGATORIES (l-2O

Pursuant to Fed. It Civ. P. 33, TriZetto Group, Inc., ("l'RIZEUO") hereby requests that

plaintiff McKesson Information Solutions, LLC ("McKESSON") respond in writing to the
following interrogatories within thirty (30) days of their service.

INSTRUCTIONS
1.

These Interrogatories are continuing in character, so as to require that

supplemental answers be filed seasonably if further or different information is obtained with
respect to any interrogatory.

2.

The terms "and" and "or" shall be construed either conjunctively or disjunctively,

as necessary, to bring within the scope of a discovery request any information which might
otherwise be construed to be outside of its scope.

3.

No part of an interrogatory should be left unanswered merely because an

objection is interposed to another part of the interrogatory. If a partial or incomplete answer is
provided, the responding party shall state that the answer is partial or incomplete.

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4.

In accordance with Fed. R. Civ. P. 26(b)(5), where a claim of privilege is asserted

in objecting to any. interrogatory or part thereof, and information is not provided on the basis of
such assertion:
A.

In asserting the privilege, the responding party shall, in the objection to the

interrogatory, or part thereof, identify with specificity the nature of the privilege (including work
product) that is being claimed;
B.

The following information should be provided in the objection, if known

or reasonably available, unless divulging such information would cause disclosure of the
allegedly privileged information,

(I)

For oral communications:

a.

the name of the PERSON making the communication and

the names of the PERSONS present while the communication was made, and, where not
apparent, the relationship of the PERSONS present to the PERSON making the communication;

b.
c:

the date and place of the communication; and the general subject matter of the communication.

(2)

For documents:
a.

the type of document, the general subject matter of the document,

b.

c.

the date of the document, and

d.

such other information as is sufficient to identify the

document, including, where appropriate, the author, addressee, custodian, and any other recipient

of the document, and where not apparent, the relationship of the author, addressee, custodian,
and any other recipient to each other.

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5.

If the responding party elects to specify and produce business recOrds in answer to

any interrogatory, the sjieciflcation shall be in sufficient detail to permit the interrogating party to

locate and identify, as readily as the responding party can, the business records from which the
answer may be ascertained.

6.

If, in answering these interrogatories, the responding party encounters any

ambiguities when construing a question, instruction, or definition, the responding party's answer
shall set forth the matter deemed ambiguous and the construction used in answering.

7.

All terms capitalized in these Interrogatories are defined in the definition section.

DEFINITIONS
1.

"YOU" or "YOUR" means McKesson Information Solutions, LLC., and any

subsidiaries, divisions, branches, predecessors or successors in business, and any entities acting

or purporting to act for or on behalf of the foregoing or who are subject to the direction or
control of the foregoing, including any present or former agents, employees, officers, directors,
insurance companies, attorneys, accountants, investigators, and consultants of the foregoing.

2.
3..

"The '164 PATENT" means U.S. Patent No. 5,253,164.

The term "DOCUMENTS" includes the plural as well as the singular, and is

synonymous with the terms "writing" and "recording" as defined in Rule 1001 of the Federal
Rules of Evidence, and is intended to include without limitation any handwritings, typewritings,
printings, photostats, photocopies, drawings, drafts, charts, photographs, e-mail, tape recordings,

filming and every other form of recording upon any tangible thing, any form of communication or representation including letters, words, numbers, symbols, pictures, sounds, or combinations

thereof, any stored information or databases, whether maintained S paper, magnetic or
electronic media, floppy disks, CD-ROMs, hard drives, zip drives, tapes or on other computer

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storage, or any other maimer including the originals, or if the originals are unavailable, the
duplicates of said DOCUMENTS, from which information can be obtained or translated.
4.

The term "PERSON" shall include both natural PERSONS and corporate or other

business entities, whether or not in the employ of.a party, and the acts and knowledge of a
PERSON are defined to include the acts and knowledge of that PERSONS directors, officers,
members, employees, representatives, agents, and attorneys.

5.

The term "IDENTIFY" means, with regards to documents, to:

(a)
(b)

describe the nature of the document (e.g., letter or memorandum); state the date of the document and its bates or control numbers, if any;

(c)

identify the PERSON who sent and received the original and any copy of
the document;

(d)

state in as much detail as possible the contents of the document; and
state the manner and date of the disposition of the document.

(e)
6.

The term "IDENTIFY," with respect to PERSONS, shall men to state the

PERSONS: (a)
Individual, company, or corporate name;
last known address; and

(b)

(c)

last known phone number.

INTERROGATORIES

INTERROGATORY NO.1:

State in detail YOUR construction of each term of each asserted claim of the '164
PATENT, by means of a claim chart (including whether YOUR construction is based on the

ordinary meaning, any intrinsic and extrinsic support for YOUR definition, whether YOU

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contend 'that any claim term has any meaning other than its ordinary meaning, and any evidence
YOU contend supports a construction other than the ordinary meaning).

INTERROGATORY NO.2:
Describe in detail how each asserted claim of the '164 PATENT has been infringed by
TRIZEUO (including, for each system or product accused of being infringed, stating in detail,
by means of a claim chart, YOUR contention as to where each limitation of the asserted claim is

found in the accused infringing TRIZETTO system or product and whether YOU are asserting
literal infringement or infringement under the doctrine of equivalents).

INTERROGATORY NO.3
For each asserted claim of the '164 PATENT, describe in detail the alleged conception of each. claimed invention (including, but not limited to, the date each claimed invention was first

conceived, the names of all PERSONS who participated in the, conception of the claimed

invention, 'the contribution made by each PERSON, and any documents related to that
conception).

INTERROGATORY NO.4:
For each asserted claim of the '164 PATENT, describe in detail the first reduction to
practice (either actual or constructive) of each claimed invention (including but not limited to the

circumstances of the reduction to practice, the date(s) of the reduction to practice, identification

of all PERSONS who participated in the reduction to practice, the contribution made by each
PERSON, and any documents that relate to that reduction to practice).

INTERROGATORY NO.5:
For each TRIZETTO system or product that YOU contend infringes the "164 PATENT,

describe the circumstances under which YOU or YOUR predecessor-in-interest first became

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aware of that system or product and its alleged infringement (including, but not limited to, the
date(s) upon which YOU or YOUR predecessor-in-interest first became aware of such product,
the date upon which YOU or YOUR predecessor-in-interest first became aware that such product

allegedly infringed the '164 patent, and identification of all PERSONS involved and all
documents relating thereto).

INTERROGATORY NO.6:
For each asserted claim of the '164 PATENT, describe any disclosures of the subject

matter thereof prior to the date on which the application for the '164 PATENT was filed
(including but not limited to, all prior written publications, all sales, all offers to sell, and/or
public uses of any product or system embodying or practicing any claimed invention of the '164

PATENT, the dates ?

any such disclosures, sales, offers for sale and/or public uses, an

identification of the products or systems sold, offered for sale and/or publicly used, and an
identification of the PERSONS involved in the disclosure, sale, offer, and/or public use and all
documents relating thereto).
·

INTERROGATORY NO.7:
IDENTIFY each product or system ever made, sold, or licensed by YOU, by YOUR
predecessor-in-interest, by the named inventors of the '164 PATENT, or by any owner, assignee,
·

or licensee of the '164 PATENT that embodies, practices, or uses any of the alleged inventions

claimed in the '164 PATENT including the specific claim(s) of the '164 !ATEIST'l' that are
embodied, practiced, âr used in or by each such product or system and the product name, model number, trade name, trademark or other indicia and the dates each product or system was made,
sold; or licensed.

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INTERROGATORY NO.8:

For each produôt or system, the identification of which is sought by, Interrpgatory
Number 7, IDENTIFY the PERSONS most knowledgeable about that product àr system and
state when it was' first described in a printed publication, publicly disclosed,, or offered for sale
and sold anywhere, in the world.

INTERROGATORY NO.9:
IDENTIFY all prior art to the '164 PATENT (including publications, patents, patent
applications, inventions by others, uses, sales or offers for sale, and disclosures) which YOU, the

named inventors of the '164 PATENT, any owner, assignee or licensee of the '164 PATENT, or
any patent agent or attorney acting on behalf of the named inventors of the '164 PATENT, were
aware prior to filing the '164 PATENT;

INTERROGATORY NO. 10:
For every item of prior art the identification of which is sought by Interrogatory No. 9,
describe how the prior art was located and the PERSON most knowledgeable about the location
of that prior art, and identify all documents relating thereto.

INTERROGATORY NO. 11:
Describe in detail any investigation, analysis, testing, studying, or reverse engineering of

every TRIZETTO product that YOU have ever considered to infringe or possibly infringe any
claim(s) of the '164 PATENT (including, but not limited to, the identification of all PERSONS

involved, the nature of each such PERSON'S involvement, the time period of the PERSON'S
involvement, any conclusions reached, and any documents relating thereto).

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INTERROGATORY NO. 12:

IDENTIFY and describe any secondary considerations or objective evidence of
nonobviousness (e.g. commercial success, long-felt need, expressions of skepticism or disbelief

copying, etc.) that YOU contend support or evidence the purported nonobviousness of the

subject matter claimed in the '164 PATENT, and identify all documents supporting such
contention.

INTERROGATORY NO. 13:
State the amount of damages to which YOU claim to be entitled from TRIZETTO in this

action, and the method used to calculate those damages, and identify all documents relating
thereto.

INTERROGATORY NO. 14:
State the royalty rate or rates YOU contend are a "reasonable royalty" under 35 U.S.C. §
284

for the alleged iifringement of the '164 PATENT, and how that royalty rate(s) was

determined (including all facts and contentions that support the use of the royalty rate, and all
DOCUMENTS that YOU contend support YOUR asserted royalty rate).

INTERROGATORY NO. 15:
iDENTIFY allreference materials, including without limitation books, publications, and

computer software, that were used or relied upon by any of the inventors of the '164 patent
during its conception, development or reduction to practice.

INTERROGATORY NO. 16:
iDENTIFY all PERSONS, in addition to the inventors, who may have contributed to the
conception, development or reduction to practice of the invention claimed in the '164 PATENT.

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INTERROGATORY NO. 17:

IDENTIFY all PERSONS involved with the conception, development or
commercialization of Health Payment Review, Inc.'s CodeReview product.

INTERROGATORY NO. 18:
Identify all materials used which were the basis of the CodeReview product, including all
prior software, medical device codes and sets of relationships among the medical device codes.

INTERROGATORY NO. 19:
IDENTIFY the programming language or languages used, and any commercial software

products used to define the programming environment and/or to assist in the coding of the

knowledge base and knowledge base interpreter portions of the system discussed in '164
PATENT as included in the patent's specification and appendices.

INTERROGATORY NO. 20:
Describe in detail the basis for YOUR allegation that TRIZET1O's alleged infringement
of the '164 Patent has been willful and wanton. MORRLS,NICHOLS, ARSHT & TUNNELL

B. Bluinenfeld (#1014) Rodger D. Smith, 11 (#3778) 1201 N.. Market Street P.O. Box 1347 · Wilmington, DE 19899 (302) 658-9200 Attorneys for Defendant The TriZetto Group, Inc. -

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OF COUNSEL: John M. Benassi

JessicaR. Wolff
Matthew C. Lapple Paul, Hastings, Janofsky & Walker LLP 3579 Valley Centre Drive San Diego, CA 92130 (858) 720-2500

December 14, 2004

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CERTIFICATE OF SERVICE

I, Jack B. Blumenfeld, hereby certi& that copies of the foregoing were caused to
be served on December 14, 2004 upon the following in the manner indicated:

BY HAND

Thomas J. Allingham, II Skadden, Arps, Slate, Meagher & Flom LLP One Rodney Square P.O. Box 636 Wilmington, DE 19899
BY FEDERAL EXPRESS

Jeffrey 0. Randall Skadden, Alps, Slate, Meagher & Flom LLP 525 University Avenue Suite 1100 Palo Alto, CA 94301]

.TJackB.eld

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EXHIBIT V

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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF DELAWARE

MCKESSON INFORMATION SOLUTIONS ) LLC, ) ) Plaintiff, v. ) ) ) TIlE TRIZETTO GROUP, INC., ) Defendant. )

CIVIL ACTION NO' 04-1258-SLR

PLAINTIFF MCKESSON'S RESPONSE TO DEFENDANT TRIZETTO'S FLRST SET OF INTERROGATORIES (1-20)
Pursnsnt to Federal Rule of Civil Procedure 33, plaintiff; McKesson Information Solutions LLC ("McKesson"), objects and responds as follows to the First Set of
Interrogatories by defendant, The TriZetto Group, Inc. ("TriZetto").

GENERAL OBJECTIONS
McKesson makes the following General Objections, whether or not separately set forth in response to each interrogatory, to each and every instruction, definition, and
question posed in the interrogatories:
1.

McKesson objects generally to interrogatories 1 through 20, inclusive,

insofar as they seek production of documents or information protected by the attorney-

client privilege, the work product inmiunity doctrine, or other privileges. Such
documents or information shall not be produced in response to any interrogatory, and any inadvertent production thereof shall not be deemed a waiver of any privilege with respect to such documents or information, or of any work product immunity doctrine or other

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INTERROGATORY NO.6:
For each asserted claim of the '164 PATENT, describe any disclosures of the subject matter thereof prior to the date on which the application for the '164 PATENT was filed (including but not limited to, all prior written publications, all sales, all offers to sell, and/or public uses of any product or system embodying or practicing any claimed invention of the '164 PATENT, the dates of any such disclosures, sales, offers for sale and/or public uses, an identification of the products or systems sold, offered for sale and/or publicly used, and an identification of the PERSONS involved in the disclosure, sale, offer, and/or public use and all documents relating thereto).

RESPONSE TO INTERROGATORY NO.6:
Subject to and without waiving its previously stated General Objections, McKesson states the following Specific Objections to this interrogatory: McKesson objects to this interrogatory as vague and ambiguous, particularly with

respect to the phrases "relating thereto" and "subject matter thereof." McKesson further
objects to this interrogatory as overbroad and unduly burdensome to the extent it seeks

information regarding the disclosure of any portion of the '164 patent or its claims. Such information could encompass, inter alia, every prior disclosure of a "computer system" or a "database." McKesson further objects to this interrogatory as overbroad and unduly burdensome to the extent it seeks information not within McKesson's possession,

custody, or control. With respect to other parties' activities, the Federal Rules of Civil
Procedure do not require McKesson to perform TriZetto's pre-trial investigation.
McKesson further objects to this interrogatory as overbroad and unduly burdensome to the extent it seeks documents and/or information regarding any disclosure by the named inventors or HPR, Inc. after September 30, 1987, as such information does not constitute

prior art to the claims of the '164 patent. McKesson further objects to this interrogatory
as compound and having multiple subparts. McKesson further objects to this

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interrogatory to the extent that it seeks information protected by the attorney-client privilege, the work product immunity doctrine, or other privileges.
-

Subject to and without waiving the foregoing objections, McKesson responds to

this interrogatory as follows: Neither TriZetto nor any third-party have identified a disclosure, publication, sale, offer for sale, or public use that invalidates any claim of the '164 patent and McKesson is not aware of any such disclosure, publication, sale, offer for

sale, or public use. To McKesson's knowledge, consistent with their obligation under 37
C.F.R. § 1.56, the inventors and prosecuting attorneys disclosed all material prior art of

which they were aware to the United States Patent and Trademark Office during the

prosecution of the '164 patent. Those prior art references are identified in the prosecution history of the '164 patent, a copy of which McKesson has produced to TriZetto. McKesson's investigation into information responsive to this interrogatory is
ongoing and McKesson reserves the right to supplement this response as discovery
continues or as circumstances otherwise warrant.

INTERROGATORY NO.7:
IDENTIFY each product or system ever made, sold, or licensed by YOU, by YOUR predecessor-in-interest, by the named inventors of the '164 PATENT, or by any owner, assignee, or licensee of the '164 PATENT that embodies, practices, or uses any of the alleged inventions claimed in the '164 PATENT including the specific claim(s) of the '164 PATENT that are embodied, practiced, or used in or by each. such product or system and the product name, model number, trade name, trademark or other indicia and the dates each product or system was made, sold, or licensed.

RESPONSE TO INTERROGATORY NO.7:
Subject to and without waiving its previously stated General Objections, McKesson states the following Specific Objections to this interrogatory:

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McKesson objects to this interrogatory as premature. Whether a product or
system "embodie[s], practice{s], or use[sJ" inventions claimed in the '164 patent requires

a construction of the patent's claims, the proper determination of which will be made by
the Court as a matter of law, and an application of that construction to a product or

system that may require expert analysis. Furthermore, McKesson's damages
investigation is ongoing and may require expert analysis which has not been completed.

Moreover, as stated in McKesson's response to Interrogatory Number 1, TriZetto's request for McKesson's claim construction contentions is premature at this time. McKesson further objects to this interrogatory's use of "YOU" and "YOUR," as those
terms are defined by TriZetto, as well as its request for information regarding any licensees' products or systems, as unduly burdensome, overbroad, and seeking

information that is not within McKesson's possession, custody, or control and/or seeking
information that is neither relevant to the claim or defense of any party nor reasonably calculated to lead to the discovery of admissible evidence. Under TriZetto' s definitions, this interrogatory calls for the contentions, if any, of innumerable third-party individuals
and entities with no connection to this action.

McKesson further objects to this interrogatory as vague and ambiguous,

particularly with respect to the phrase "alleged inventions." The United States Patent and
Trademark Office issued the '164 patent after due consideration of the prior art and all requirements. for patentability. Accordingly, each claim of the '164 patent is presumed,

as a matter of law, to describe a patentable invention. McKesson further objects to this interrogatory as compound and having multiple subparts. McKesson further objects to

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this interrogatory to the extent that it seeks information protected by the attorney-client
privilege, the work product immunity doctrine, or other privileges.

Subject to and without waiving the foregoing objections, McKesson responds to this interrogatory as follows: Neither TriZetto nor any third-party have identified a sale
or offer for sale that invalidates any claim of the '164 patent and McKesson is not aware

of any such sale or offer for sale. To McKesson's knowledge, consistent with their
obligation under 37 C.F.R. § 1.56, the inventors and prosecuting attorneys disclosed all material prior art of which they were aware to the United States Patent and Trademark

Office during the prosecution of the '164.patent. Those prior art references are identified
in the prosecution history of the '164 patent, a copy of which McKesson has produced to

TriZetto. McKesson's investigation into information responsive to this interrogatory is
ongoing and McKesson reserves the right to supplement this response as discovery
continues or as circumstances otherwise warrant.

INTERROGATORY NO.8:
For each product or system, the identification of which is sought by Interrogatory No. 7, IDENTiFY the PERSONS most knowledgeable about that product or system and state when it was first described in a printed publication, publicly disclosed, or offered for sale and sold anywhere in the world:

RESPONSE TO INTERROGATORY NO.8:
Subject to and without waiving its previously stated General Objections, McKesson states the following Specific Objections to this interrogatory. McKesson objects to this interrogatory for the same reasons stated in response to Interrogatory Number 7 and incorporates its response and objections to that interrogatory
herein in their entirety.

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McKesson's investigation into information responsive to this interrogatory is
ongoing and McKesson reserves the right to supplement this response as discovery
continues or as circumstances otherwise warrant.

INTERROGATORY NO.9:
IDENTIFY all prior art to the '164 PATENT (including publications, patents, patent applications, inventions by others, uses, sales or offers for sale, and disclosures) which YOU, the named inventors or the '164 PATENT, any owner, assignee or licensee of the '164 PATENT, or any patent agent or attorney acting on behalf of the named inventors of the '164 PATENT, were aware prior to filing the '164 PATENT.

RESPONSE TO INTERROGATORY NO.9:
Subject to and without waiving its previously stated General Objections, McKesson states the following Specific Objections to this interrogatory: McKesson objects to this interrogatory as vague and ambiguous, particularly with

· respect to the phrases "filing the '164 PATENT" and "prior art to the '164 PATENT."
Without further definition or limitation to a particular field, this interrogatory is overbroad and unduly burdensome andlor improperly calls for a legal determination of

what constitutes "prior art to the '164 PATENT." McKesson further objects to this
interrogatory as overbroad and unduly burdensome to the extent it seeks information regarding the awareness of any individuals other than the named inventors and

prosecuting attorneys, as such information is neither relevant to the claim or defense of
any party nor reasonably calculated to lead to the discovery of admissible evidence.

McKesson further objects to this interrogatory's use of the term "YOU," as that term is
defined by TriZetto, as unduly burdensome, overbroad, and seeking information that is not within McKesson's possession, custody, or control and/or seeking information that is neither relevant to the claim or defense of any party nor reasonably calculated to lead to

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the discovery of admissible evidence. TriZetto's definition calls for information
regarding the awareness, if any, of innumerable third-party individuals and entities with no connection to this action. McKesson further objects to this interrogatory as compound and having multiple subparts. McKesson further objects to this interrogatory to the
extent that it seeks information protected by the attorney-client privilege, 'the work
product irnmuiiity doctrine, or other privileges.

Subject to and without waiving the foregoing objections, McKesson responds to

this interrogatory as follows: To McKesson's knowledge, consistent with their obligation
under 37 C.F.R. § 1.56, the inventors and prosecuting attorneys disclosed all material prior art of which they were aware to the United States Patent and Trademark Office

during the prosecution of the '164 patent. Those prior art references are identified in the prosecution history of the '164 patent, a copy of which McKesson has produced to TriZetto. McKesson's investigation into information responsive to this interrogatory is
ongoing and McKesson reserves the right to supplement this response as discovery continues or as circumstances otherwise warrant.

INTERROGATORY NO. 10:
For every item of prior art the identification of which is sought by Interrogatory No. 9, describe how the prior art was located and the PERSON most knowledgeable about the location of that prior art, and identify all documents relating thereto.

RESPONSE TO INTERROGATORY NO. 10:
Subject to and without waiving its previously stated General Objections, McKesson states the following Specific Objections to this interrogatory: McKesson objects to this interrogatory for the same reasons stated in response to Interrogatory Number 9 and incorporates its response and objections to that interrogatory

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herein in their entirety. McKesson further objects to this request as vague and
ambiguous, particularly with respect to the phrases "how the prior art was located,"

"location," and "relating thereto." McKesson further objects to this request as overbroad
and unduly burdensome to the extent it seeks information regarding "how the prior art

was located," as such information is neither relevant to the claim or defene of any party
nor reasonably calculated to lead to the discovery of admissible evidence. McKesson
further objects to this interrogatory to the extent that it seeks information protected by the attorney-client privilege, the work product immunity doctrine, or other privileges. Subject to and without waiving the foregoing objections, McKesson responds to

this interrogatory as follows: To McKesson's knowledge, consistent with their obligation
under 37 C.F.R. § 1.56, the inventors and prosecuting attorneys of the '164 patent

disclosed all material prior art ofwhich they were aware to the United States Patent and

Trademark Office during the '164 patent's prosecution. Those prior art references are
identified in the prosecution history of the '164 patent, a copy of which McKesson has

produced to TriZetto. McKesson's investigation into information responsive to this
interrogatory is ongoing and McKesson reserves the right to supplement this response as
discovery continues or as circumstances otherwise warrant.

INTERROGATORY NO. 11:
Describe in detail any investigation, analysis, testing, studying, or reverse engineering of every TRIZETTO product that YOU have ever considered to infringe or possibly infringe any claim(s) of the '164 PATENT (including, but not limited to, the identification of all PERSONS involved, the nature of each such PERSON'S involvement, the time period of the PERSON'S involvement, any conclusions reached, and any documents relating thereto).

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DATED: January 13,2005

Jeffery .J1anda11

SKADIN, ARPS, SLATE EAGHER
& FLO1(4 LLP 525 University Avenue, Suite 1100

Palo Alto, CA 94301
Attorneys for Plaintifi McKesson Inforniation Solutions LLC

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EXHIBIT W

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EXHIBIT X

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EXHIBIT Y

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
MCKESSON INFORMATION SOLUTIONS LLC,

Plaintiff, v. THE TRIZETTO GROUP, INC.
Defendant.

Civil Action No. 04-1258-SLR

DEFENDANT'S DESIGNATION OF TRIAL WITNESSES

Pursuant to paragraph 2(f) of the February 18, 2005, Scheduling Order herein,
defendant The TriZetto Group, Inc. hereby identifies the following fact witnesses that it

may call at one or both of the trials herein, either in person or by way of deposition
testimony:
1.

Bargar, Robert Bell, Karen Bellomo, Anthony

13.

Dugan, Kelli Egdahl, Richard
Goldberg, George

2. 3.
4. 5. 6. 7. 8. 9.
10.

14. 15. 16. 17.

Blake, John Blakely, Roger Bowker, Michael
Cesarz, Michael

Graham,Steve
Hawley, Philip

18. Hemp, Kristen
19.

Hertenstein, Robert
Holloway, Donald Hurst, Ronald

Cutcliff, Janet

20. 21. 22.
23. 24.

Danza, John Davis, Randall
Demers, Don
Doubleday, Chris

Jones, Clifton Kao, John Kerschberg, Larry

11. 12.

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25.

King, Eric

32. 33. 34. 35. 36. 37.

Owen, Mark

26.

Kiplinger, Patricia

Radosevich, Marcia
Richardson, Duffey
Siemens, Gunter

27. Lampe, Karen
28. 29.
Luftig, Craig

Margolis, Jeffrey

Smith, Tara
Smith, Tommy

30. Moore, Charlie
31.

Nunnelly, John

38.

Wukitch, Carolyn

TriZetto reserves the right to supplement and amend the foregoing list with
additional witnesses based on further investigation and review, and based on additional
discovery recently ordered by Judge Bechtle. TriZetto also reserves the right to call any witnesses designed by McKesson in this matter, and to designate the same or additional
witnesses for purposes of impeachment and/or rebuttal. MORRIS, NICHOLS, ARSHT & TUNNELL

L
Ja

B. Blumenfeld (#014)

odger D. Smith, II (#3778) 1201 North Market Street P.O. Box 1347 Wilmington, Delaware 19899-1347 (302) 658-9200 Attorneys for Defendant THE TRIZETTO GROUP, INC.

OF COUNSEL:

Jeffrey T. Thomas David A. Segal Michael A. Sitzman GIBSON, DUNN & CRUTCHER LLP Jamboree Center, 4 Park Plaza Irvine, California 926 14-8557 (949) 451-3800
December 30, 2005

2

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CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that copies of the foregoing were caused to be

served this 30th day of December, 2005, upon the following counsel in the manner
indicated: BY HAND Thomas J. Allingham, II SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP One Rodney Square P.O. Box 636 Wilmington, DE 19899 BY FEDERAL EXPRESS Jeffrey G. Randall SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP 525 University Avenue Palo Alto, CA 94301

8

Jack B. Bluicienfeld

IL4U

2

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EXHIBIT Z

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