UNITED STATES DISTRICT COURT FOR 

THE DISTRICT OF NEW HAMPSHIRE 

IMS HEALTH INCORPORATED, a Delaware ) 

corporation and VERISPAN, LLC, a Delaware ) 

limited liability company, ) 

 ) 

 Plaintiffs, ) 

 ) Case No. 06-CV-280-PB 

vs. ) 

 ) 

KELLY A. AYOTTE, as Attorney General of ) 

the State of New Hampshire, ) 

 ) 

Defendant ) 

STATE’S WITNESS LIST

 NOW COMES the State of New Hampshire (the “State”), by and through the Office of 

the Attorney General, and respectfully submits the following Witness List for trial in the above 

referenced matter. 

 1. Dr. Jerry Avorn 

 Professor of Medicine, Harvard Medical School 

 Chief, Division of Pharmacoepidemiology and Pharmacoeconomics 

 Brigham and Women's Hospital 

 1620 Tremont Street, Suite 3030 

 Boston, MA 02120 

 (617) 278-0930 

 2. Dr. Aaron S. Kesselheim 

 Division of Pharmacoepidemiology and Pharmacoeconomics 

 Brigham and Women’s Hospital 

 1620 Tremont St., Suite 3030 

 Boston MA 02115 

 (617) 278-0930 

3. Dr. Gary A. Sobelson 

Concord Family Medicine 

141 East Side Drive 

Concord, NH. 03301 

(603) 225-3427 

Case 1:06-cv-00280-PB Document 72 Filed 12/22/2006 Page 1 of 3
 4. Dr. Marc Sadowsky 

 New England Neurological Associates 

 Medical Arts Building 

 168 Kinsley Street, Suite #1 

 Nashua, NH 03061 

 (603) 882-2114 

 

 5. Shahram Ahari 

 1524 Berkeley Way, Apt A 

 Berkeley, CA 94703 

 cell: (510) 684-8509 

 6. The Defendant reserves the right to present testimony, by reference to deposition 

transcripts or portions of deposition video, or to call any witness listed by the Plaintiffs. 

 7. The Defendant reserves the right to call rebuttal or impeachment witnesses not listed or 

identified herein as necessary and as allowed by the Court, depending on the evidence 

allowed at trial. 

 8. In accordance with the Discovery Plan (Court document No. 34), and the Order 

approving the Discovery Plan, the Defendant designates the declarations and depositions 

described in its Exhibit List, filed concurrently with this Witness List. 

All parties have submitted witness declarations to the Court. The video depositions of all of the 

State’s witnesses and many of the Plaintiffs’ witnesses have been taken. The State’s position is 

that all witnesses for both parties can be submitted by declaration, deposition transcript and 

video, with relevant portions to be presented in argument to the Court. 

Respectfully submitted, 

 THE STATE OF NEW HAMPSHIRE 

 Kelly A. Ayotte 

 Attorney General 

 

Date: 12/22/2006 /s/Richard W. Head 

 By: Richard W. Head (N.H. Bar No. 7900) 

 Senior Assistant Attorney General 

David A. Rienzo (N.H. Bar No. 13860) 

Assistant Attorney General 

Laura E. B. Lombardi (N.H. Bar No. 12821) 

Assistant Attorney General 

Case 1:06-cv-00280-PB Document 72 Filed 12/22/2006 Page 2 of 3
 33 Capitol Street 

 Concord, New Hampshire 03301 

 (603) 271-3643 

Certification of Service

 I hereby certify that a copy of the foregoing document was filed electronically and served 

electronically by operation of the Court’s electronic filing system or by mail on anyone unable to 

accept electronic filing. Jeffrey C. Spear, Esquire, James Bassett, Esquire, Patricia Acosta, 

Esquire and Thomas R. Julin, Esquire have appeared as counsel of record for plaintiffs IMS 

Health Incorporated and Verispan, LLC. 

 

 /s/Richard W. Head 

 By: Richard W. Head (N.H. Bar No. 7900) 

Case 1:06-cv-00280-PB Document 72 Filed 12/22/2006 Page 3 of 3