Free Redacted Document - District Court of Delaware - Delaware

Case 1 :04-cv-01258-SLR Document 194 Filed 12/23/2005 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT ` _
FOR THE DISTRICT OF DELAWARE
MCKESSON INFORIvLATION SOLUTIONS )
LLC, l CIVIL ACTION NO. 04-1258-SLR ‘
Plaintiff )
) REDACTED PUBLIC VERSION
v.
_ THE TRIZETTO GROUP, INC', g Confidential Version Filed December 20, 2005
Defendant. l Redacted Public Version Filed December 23, 2005
DECLARATION OF MICHAEL A. BARLOW IN SUPPORT OF
PLAINTIFF’S OPENING BRIEF IN SUPPORT OF ITS MOTION TO
EXCLUDE AND/OR STRIKE THE OPINIONS OF JESSE DAVID, PH.D.
I, Michael A. Barlow, pursuant to 28 U.S.C. § 1746. declare as
follows:
1. I am an attorney ofthe Bar of the State of Delaware and of the
firm of Skadden, Arps, Slate, Meagher & Flom LLP, attorneys for plaintiff
McKesson Infomation Solutions LLC in the above—captioned action. I submit this
declaration in support of the Plaintiff s Opening Brief in Support of its Motion to
Exclude and/or Strike the Opinions of Jesse David', Ph.D., and to transmit to the
Court true and correct copies ofthe following documents attached as exhibits hereto: _

Case 1 :04-cv-01258-SLR Document 194 Filed 12/23/2005 Page 2 of 3
Description l Exhibit N0.
Table entitled "Previously Unproduced TriZetto Documents Referenced in A
Jesse David‘s Expert Report" _
Rebuttal Expert Report of Jesse David, dated November 17, 2005 B
l Excerpts from the deposition of Jesse David, P11.D. taken November 30, C
2005
Excerpts from Defendant the 'J`riZetto Group, I.nc.'s Response to McKesson . D l
Information Solutions LLC's First Set of Requests for the Production of
Documents and Things, dated January 20, 2005
Excerpts from The TriZetto Group, Inc.'s Supplemental Response to E
Plaintiffs Interrogatories Nos. 5, 8, 10, 11 & 14-17
- Notice of Deposition of Defendant TriZetto Pursuant to Fed. R. Civ. P. F .
30(b)(6)
Letter dated August 26, 2005 from Jeff Randall to Jeff Thomas G
Letter dated August 31, 2005 from Jeff Randall to Michael Sitzman H
Letter dated September 6, 2005 from T. Kevin Roosevelt to Bernard C. 1
Shek, David W. Hansen and Jeffrey G. Randall
Email dated September 15, 2005 from Michael Sitzman to Jeff Randall, J
Bernard Shek and David Hansen _
Defendants Supplemental Response to Plaintiffs Rule 30(b)(6) Deposition K
Notice, dated October 31, 2005
Excerpts from the transcript from Court Hearing on November 7, 2005 L
Defendanfs Supplemental Response to Plaintiffs Rule 30(b)(6) Deposition M
Notice, dated November 18, 2005
Letter dated November 17, 2005 from Gabrielle J. Roudabush to David W. N
Hansen
' 2

Case 1:04-cv—01258-SLR Document 194 Filed 12/23/2005 Page 3 of 3
I declare under penalty of pexjury that the foregoing is true and
correct.
Executed: December 20, 2005.
Michael A. Barlow (LD. # 3928)
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