Free Statement - District Court of Delaware - Delaware

Case 1 :05-cv-00292-JJF Document 202 Filed 05/31 /2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
LGPHILIPS LCD CO., LTD., I
Plaintiff/Counterclaim Defendant, i
I
V· i . . .
{ C1v1l Action N0. 05~292 (UF)
TATUNG COMPANY; l
TATUNG COMPANY OF AMERICA, INC.; r
CHUNGHWA PICTURE TUBES, LTD.; l
AND VIEWSONIC CORPORATION, {
Defendants/Counterclaim Plaintiffs. i

LOCAL RULE 7.1.1 STATEMENT IN SUPPORT OF
PLAINTIFF’S SECOND MOTION TO COMPEL DEPOSITION TESTIMONY
AND FOR SANCTIONS |D.I. 199]
The undersigned attorney for plaintiff LG.Philips LCD Co., Ltd. ("LPL") hereby states,
pursuant to Local Rule 7.1.1, that LPL’s attorneys have made a reasonable effort to reach
agreement with opposing counsel on the matters set forth in LPL’s Second Motion to Compel
Deposition Testimony and for Sanctions (the "Second Motion") [DI. 199]. Specifically, counsel
states the following:
(1) The Second Motion deals with depositions LPL is taking of defendants on an
expedited basis in preparation for the trial that will commence on July 17. The Second Motion
seeks relief as a result of (a) defendants’ presentation of corporate witnesses inadequately
prepared to testify under Fed. R. Civ. P. 30(b)(6); and (b) defense counsel’s repeated improper
consultation with deponents during the course of depositions.
(2) LPI./s counsel asked defense counsel to present corporate witnesses adequately
prepared to testify under Ped. R. Civ. P. 30(b)(6), but defense counsel stated their belief that the
witnesses were adequately prepared. LPL’s counsel also asked the witnesses to disclose the
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Case 1:05-cv-00292-JJF Document 202 Filed 05/31/2006 Page 2 of 3
substance of discussions with counsel that took place during the depositions concerning
testimony, but counsel refused to allow the witnesses to answer those questions.
May 31, 2006
THE BAYARD FIRM
(Richard D. Kirk (rk0922)
222 Delaware Avenue, Suite 900
P.O. Box 25130
Wilmington, DE 19899-5130
(302) 655-5000
[email protected]
Counsel for plaintiff,
LG.Philips LCD Co., Ltd.
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Case 1:05-cv-00292-JJF Document 202 Filed 05/31/2006 Page 3 of 3
CERTIFICATE OF SERVICE
The undersigned counsel certifies that, on May 31, 2006, he electronically filed
the foregoing document with the Clerk ofthe Court using CM/ECE, which will send
automatic notification of the filing to the following:
Robert W. Whetzel, Esq.
Matthew W. King, Esq.
Richards, Layton & Finger
One Rodney Square
P.O. Box 551
Wilmington, DE 19899
The undersigned counsel further certifies that copies of the foregoing document
were sent on May 31, 2006 by email and by hand to the above counsel and by email and
first class mail to the following non—registered participants:
Christine A. Dudzik, Esq. Teresa M. Corbin, Esq.
Thomas W. Jenkins, Esq. Glenn W. Rhodes, Esq.
Howrey LLP Julie Gabler, Esq.
321 North Clark Street Howrey LLP
Suite 3400 525 Market Street
Chicago, IL 60610 Suite 3600
San Francisco, CA 94105
/s/ Richard D. Kirk grk0922l
Richard D. Kirk
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