UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF NEW YORK 

 

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IN RE BRISTOL-MYERS SQUIBB CO. 

SECURITIES LITIGATION 

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07 Civ. 5867 (PAC) 

FILED 

ELECTRONICALLY 

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DECLARATION OF LORIN L. REISNER 

IN SUPPORT OF MOTION TO DISMISS

Lorin L. Reisner hereby declares as follows: 

1. I am a member of the bar of this Court and the law firm Debevoise & 

Plimpton LLP, counsel for defendant Bristol-Myers Squibb Company (“BMS”). This 

declaration is submitted in support of the motion to dismiss this action. 

2. Attached as Exhibit A is a true and correct copy of excerpts of a Form 10-

K publicly filed by BMS on March 15, 2004. 

3. Attached as Exhibit B is a true and correct copy of excerpts of a Form 10-

Q publicly filed by BMS on May 10, 2004. 

4. Attached as Exhibit C is a true and correct copy of excerpts of a Form 10-

Q publicly filed by BMS on May 9, 2005. 

5. Attached as Exhibit D is a true and correct copy of excerpts of a Form 10-

K publicly filed by BMS on March 14, 2006. That document is referenced in paragraph 

61 of the Amended Complaint. 

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6. Attached as Exhibit E is a true and correct copy of a Form 8-K publicly 

filed by BMS on March 21, 2006. That document is referenced in paragraphs 2, 33-34, 

36-37, 58 and 60-66 of the Amended Complaint. 

7. Attached as Exhibit F is a true and correct copy of excerpts of a Form 8-K 

publicly filed by BMS on April 27, 2006. That document is referenced in paragraphs 3 

and 67-69 of the Amended Complaint. 

8. Attached as Exhibit G is a true and correct copy of excerpts of a Form 10-

Q publicly filed by BMS on May 8, 2006. That document is referenced in paragraphs 4, 

16, 73, 74 and 75 of the Amended Complaint. 

9. Attached as Exhibit H is a true and correct copy of a press release issued 

by BMS on June 25, 2006. That document is referenced in paragraphs 40, 79, 80 and 81 

of the Amended Complaint. 

10. Attached as Exhibit I is a true and correct copy of excerpts of a Form 8-K 

publicly filed by BMS on July 27, 2006. That document is referenced in paragraphs 6, 

52, 82 and 86 of the Amended Complaint. 

11. Attached as Exhibit J is a true and correct copy of a press release issued by 

BMS on July 28, 2006. That document is referenced in paragraphs 87-88 of the 

Amended Complaint. The release reflects that it was issued on July 29, 2006 at 12:02 

a.m. Greenwich Mean Time, corresponding to July 28, 2006 at 8:02 p.m., Eastern 

Daylight Saving Time. 

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12. Attached as Exhibit K is a true and correct copy of excerpts of a Form 10-

Q publicly filed by BMS on August 8, 2006. That document is referenced in paragraphs 

7, 16, 41, 53, 95 and 111 of the Amended Complaint. 

13. Attached as Exhibit L is a true and correct copy of a press release issued 

by BMS on August 31, 2006. The release reflects that it was issued on September 1, 

2006 at 1:30 a.m. Greenwich Mean Time, corresponding to August 31, 2006 9:30 p.m. 

Eastern Daylight Saving Time. 

14. Attached as Exhibit M is a true and correct copy of a press release issued 

by BMS on December 8, 2006. The release reflects that it was issued 6:27 p.m. 

Greenwich Mean Time, corresponding to 1:27 p.m. Eastern Standard Time. 

15. Attached as Exhibit N is a true and correct copy of excerpts of a Form 10-

Q publicly filed by BMS on May 10, 2007. 

16. Attached as Exhibit O is a true and correct copy of a press release issued 

by BMS on May 10, 2007. That document is referenced in paragraphs 56 and 107 of the 

Amended Complaint. The release reflects that it was issued 8:41 p.m. Greenwich Mean 

Time, corresponding to 4:41 p.m. Eastern Daylight Saving Time. 

17. Attached as Exhibit P is a true and correct copy of a press release issued 

by BMS on June 11, 2007. That document is referenced in paragraphs 57 and 108 of the 

Amended Complaint. 

18. Attached as Exhibit Q is a true and correct copy of a press release issued 

by BMS on June 19, 2007. The release reflects that it was issued 3:02 p.m. Greenwich 

Mean Time, corresponding to 11:02 a.m. Eastern Daylight Saving Time. 

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19. Attached as Exhibit R is a chart that sets forth the daily closing price per 

share of BMS common stock on each trading day from March 21, 2006 through June 19, 

2007. The information in this exhibit was obtained from a database maintained by 

Bloomberg LLP, and is also available from the BMS website. 

20. Attached as Exhibit S is a true and correct copy of a press release issued 

by Apotex dated August 8, 2006 announcing its generic launch. The August 8, 2006 

Apotex generic launch is referenced in paragraph 99 of the Amended Complaint. 

21. Attached as Exhibit T is a true and correct copy of an article from the 

Newark Star Ledger entitled “Generic Plavix Hits the Market,” dated August 9, 2006. 

That document is referenced in paragraph 102 of the Amended Complaint. 

22. Attached as Exhibit U is a true and correct copy of an article from The 

Houston Chronicle entitled “Drug Fight Escalates; Bristol-Myers Shares Slip After Rival 

Launches Generic Version of Blood Thinner,” dated August 9, 2006. That document is 

referenced in paragraph 101 of the Amended Complaint. 

23. Attached as Exhibit V is a true and correct copy of an article from The 

New York Times entitled “Marketers of Plavix Outfoxed on a Deal,” dated August 9, 

2006. That document is referenced in paragraph 100 of the Amended Complaint. 

24. Attached as Exhibit W is a true and correct copy of a docket sheet for 

Sanofi-Synthelabo v. Apotex, Inc., 02 Civ. 2255 (SHS) (S.D.N.Y.), as of November 9, 

2007. 

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25. Attached as Exhibit X is a true and correct copy of a docket sheet for

Sanofi-Aventis v. Teva Pharm. USA, Inc., 04 Civ. 07548 (SHS) (S.D.N.Y), as of 

November 9, 2007. 

26. Attached as Exhibit Y is a true and correct copy of a docket sheet for 

Sanofi-Synthelabo v. Dr. Reddy’s Labs, 02 Civ. 03672 (SHS) (S.D.N.Y.), as of 

November 9, 2007. 

 I declare under penalty of perjury that the foregoing is true and correct. 

 /s/ Lorin L. Reisner

 Lorin L. Reisner 

Dated: New York, New York 

November 12, 2007 

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