Free Letter - District Court of Delaware - Delaware

Case1:04—cv-01371-JJF Document 86-3 Filed 08/22/2005 Page1 0f3
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Case 1 :04-cv-01371-JJF Document 86-3 Filed 08/22/2005 Page 2 of 3 L
FISH 8c RICHARDSON P. C.
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wie Richardson VIA FACSIMILE Q U.S. MAIL
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August 17, 2005 "° “’”°"
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Orrick Herrington & Sutcliffe LLP , R-
’ Mahal Headley
1000 Marsh Road (6,0) 8,95,39 ·
Menlo Park, CA 94025
Email
[email protected]
Re: Power Integrations Inc. v. Fairchild Semiconductor Intemational
Q USDC-D. Del. - C.A. No. 04-1371-JJF
Dm Bw
"°"°" Enclosed please find individual deposition notices which we will be filing with the
rmms court tomorrow morning for various Fairchild employees, including employees of
uuuuwuuu Fairchild’s wholly-owned subsidiary Fairchild Semiconductor Korea. By now we
N", YORK have discussed all of the noticed employees who might be employed abroad, but as
we MGC you have not confirmed the status of the employees who are planning to leave
Fairchild Korea we have enclosed notices for them as well.
""N CWM I have included place-holder dates for the various depositions for which we have not
wusmumuu, uc yet discussed specific dates, and we will work with you to reschedule these
depositions as needed. Many of these depositions will no doubt be short, and we
hope that the earlier depositions will eliminate the need to depose some of these
individuals altogether. For example, we hope that the deposition of C.S. Lim will
prevent the need to depose Y.C. Ryu, the other designer listed on the schematics for
the Fairchild 0165 devices. We similarly anticipate that the deposition of K.O Jang
will limit the testimony we need to take hom M.H. Kim, fellow designer of the 200
series devices.
We are likely to identify further witnesses for deposition in the future, particularly
given the outstanding motion to amend and Fairchi1d’s recent production of nearly
275,000 pages of documents, but I wanted to get you these notices to help you to plan
accordingly.

Case 1 :04-cv-01371-JJF Document 86-3 Filed 08/22/2005 Page 3 of 3 fi
Fist-I ac RICHARDSON 1¤.c.
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August 17, 2005
Page 2
Let me know if you will not provide any of these witnesses for depositions in their
individual capacities so that we can resolve the issue before traveling to Korea.
Sincerely,
Michael R. Headley/{g3?}/K
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Enclosures
50294663.doc