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` Case 1:04-cv—00833-KAJ Document 190-11 Filed 01/16/2006 Page 1 012 -

Case 1 :04-cv—00833-KAJ Document 190-11 Filed 01/16/2006 Page 2 of 2 ·
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Michael S. Gugig
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November ll, 2005
VISA FEDERAL EXPRESS -- SATURDAY DELIVERY
Daniel Boehnen
McDonnell Boehnen Hubert & Berghoff LLP
300 South Wacker Drive __
A Chicago, IL 60606-6709
Dear Dan: A ¤
Per our recent conversations, we have reviewed the documents previously withheld as
privileged in light of Sicor’s assertion of an advice of counsel defense against Phannacia’s
willfulness claims. Enclosed is a production set of the previously withheld documents that we
believe are within the scope of the privilege waiver associated with Sicor’s assertion of that
defense. ,
We will provide you with an updated privilege log shortly. In addition, certain
documents have been produced in redacted form. Where portions of documents do not address
issues relating to the patent at issue and are redacted on that basis, they have been marked
"redacted." Where portions of documents contain discussions of litigation strategy -- as opposed
to the opinion of counsel with respect to the validity of the patent at issue -- and are redacted on
1 that basis, they have been marked "redacted as work product." _
Please feel free to contact me with any questions you m/ay have. `
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cc: Reid Ashinoff
Jordan Sigale
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Case 1:04-cv-00833-KAJ

Document 190-11

Filed 01/16/2006

Page 1 of 2

Case 1:04-cv-00833-KAJ

Document 190-11

Filed 01/16/2006

Page 2 of 2