Free Statement - District Court of Delaware - Delaware

Case 1:05-cv-00023-JJF

Document 129

Filed 02/14/2008

Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE DOW CHEMICAL CANADA, INC. on its own behalf and as assignee of THE DOW CHEMICAL COMPANY, ) ) ) ) Plaintiff, ) ) v. ) ) HRD CORPORATION ) (d/b/a Marcus Oil & Chemical), ) ) Defendant, Counterclaim Plaintiff, )

C.A. No. 05-23 (JJF)

LOCAL RULE 7.1.1 CERTIFICATION Counsel for Defendant/Counterclaim Plaintiff HRD Corporation d/b/a Marcus Oil & Chemical hereby certifies that reasonable efforts were made to reach agreement with Plaintiffs/Counterclaim Defendants Dow Chemical Canada, Inc. and The Dow Chemical Company regarding the matters set forth in the Motion For Protective Order that was filed on February 13, 2008, and that the parties were unable to reach a complete agreement with respect to those matters. Details of counsel's efforts to reach agreement are set forth in Exhibits B through K to the motion. OF COUNSEL: Michael Landrum William C. Ferebee O'DONNELL FEREBEE MEDLEY & KEISER, PC 450 Gears, Eighth Floor Houston, TX 77067-4512 (281) 875-8200 (telephone) (281) 875-4962 (facsimile) Dated: February 14, 2008
848527/28882

POTTER ANDERSON & CORROON LLP By: /s/ W. Harding Drane, Jr. W. Harding Drane, Jr. (#1023) Richard L. Horwitz (#2246) Suzanne M. Hill (#4414) Hercules Plaza, 6th Floor 1313 N. Market Street Wilmington, DE 19899-0951 (302) 984-6000 [email protected] [email protected] [email protected] Attorneys for HRD Corporation