Free Letter - District Court of Delaware - Delaware

Case 1:04-cv—O1373-KAJ Document 245 Filed O4/O3/2006 Page 1 of 1
PRICKETT, ]0NEs & ELLIOTT
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April 3, 2006
VIA EFILING AND HAND DELIVERY
The Honorable Kent A. Jordan
United States District Court
844 King Street
Wilmington, DE 19801
RE: Ampex Corp. v. Eastman Kodak C0., et al.
C.A. N0. 04-1373 (KA]!
Dear Judge Jordan:
I write in response to Jack Blumenfeld’s letter to the Court of earlier today.
Ampex argues that it is inconsistent for defendants’ expert, Richard Taylor, to rely in his
expert report upon admissions of Ampex’s expert, Eric Anderson, while at the same time
defendants seek to disqualify Mr. Anderson as an expert. Defendants do not agree. Defendants’
Motion to Disqualify Eric Anderson has not yet been granted and there is, of course, no
guarantee that it will be granted. As a result, as of the time Mr. Taylor submitted his expert
report, Eric Anderson remained an expert witness in this case. In fact, Mr. Anderson submitted
an expert report on the same day that Mr. Taylor submitted his expert report. If, however,
Defendants’ Motion to Disqualify Eric Anderson is granted, Mr. Taylor will no longer seek to
rely upon Mr. Anderson’s admissions.
Respectfully submitted, C
PAUL M. LUKOFF
PML/mhl
cc: Clerk, U.S. District Court (By Hand)
Jack B. Bltunenfeld, Esq. (By Hand & Efiling)
Norman H. Beamer, Esq. (By E-mail)
Jesse J. Jenner, Esq. (By E-mail)
Michael J. Summersgill, Esq. (By E-mail)
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