Free Declaration - District Court of Delaware - Delaware

Case1:04—cv-01371-JJF Document 270-9 Filed 06/12/2006 Page1 0f4
E h ` b `t J

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Case 1 :04-cv-01371-JJF Document 270-9 ‘ Filed 06/12/2006 Page 2 of 4 _
S H ® Jeffrey Ft Brac¤l¤¤¤
325 l\l. St. Paul Street, Suite 4450 V
I ‘ Dallas, Texas 75201 ‘
_ LLP __ 214-593-91 as raigprmne
214-593-9111 Facsimile
· [email protected]
May 19, 2006
VIA FACSIMILE
lVlr. Michael R. Headley _
Fish & Richardson, P.C.
500 Arguello Street, Suite 500
Redwood City, California 94063 C
Re: Power Integrrziions, [nc. v. Fairchild Semiconductor International, et al.,
CA No. 04-1371 UF in the United States District Court for the District of
Delaware, Subpoena Dated May 9, 2006 to Intersil Corporation
Dear Michael:
Thank you for conferring with me today regarding the above-referenced _
subpoena Pursuant to our agreement, the return date for the document portion of the
subpoena is extended to Friday, May 26, 2006. We have agreed that, in lieu of
production of documents in Delaware, a copy of any documents that lntersil produces
will be delivered to your Redwood City, California oftice. I anticipate that, subject to
appropriate conlidentiality designations, lntersil will be able to produce to you by the
May 26, 20.06 certain documents to which lntersil does not object. However, in the
event that lntersil will 11ot be able to produce to you by Friday the 26m the docinnents to
which lntersil does not interpose an objection, I have agreed to notify you of that fact
and furnish an alternate date by noon (your time) on Monday, May 22, 2006.
With respect to the portion of the subpoena that requires the appearance of a
witness in Delaware on May 24, 20CC, we agreed that Power lntegrations will defer any
oral deposition pending your review ofthe documents produced.
To the extent that Power Integrations still desires to take an oral deposition after
your review of the doctnnents, we will confer again regarding an available date and a
suitable location for the deposition. Also, since lim Beasom has already been deposed
in the referenced matter, it may be feasible, as an alternative, to designate portions of
his transcript as the “corporate testimony" of Intersil. We also agreed that agreements
that we reached are without prejudice to the right of Intersil to make objections to the
subpoena and to tile a motion to quash, and that any objections and/or motions to quash -

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Case 1:04-cv-01371-JJF Document 270-9 Filed 06/12/2006 Page 3 of 4
SHoneCH/tw
BRAGALUNELLP
Mr. Michael R. Headley
May 19, 2006
‘ Page 2
related to the subpoena will be tiled and served by the revised return date of May 26,
2006. Please note that, as I mentioned in the call today, Intersil may want to obtain a
ruling from the Court on its motion to quash and/or obj eotions prior to the
commencement of any oral deposition.
Please let me know immediately if you believe that this letter has inadvertently
omitted any of the agreements that we reached today, and thank you again for your
cooperation in this matter.
Sincerely,
-.t-
J it Bragalo `
cc: G. Hopkins Guy, IH, Esq. . l

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Case 1 :04-cv-01371-JJ F Document 270-9 Filed 06/12/2006 Page 4 of 4
§H® E
Cl—lA1\l LLP
Arioimnvs 8:: Co uwsetons AT LAW
F AX TWSMISSION
May 19, 2006
NAN[E FAX PHONE
T0: Michael R. Headley 65{L839.5071 650-839-5070
G. Hopkins Guy, IH 650614.740] 650.614.7400
Orrick, Herrington &
Sutcliffe LLP
From: Jeffrey R. Bragalone
Direct Dial: (214) 593.9135
Re: Power Integrations, Inc. v. Fairchild Semiconductor International, Inc.
Total Pages: 3
Message: Please see attached and thank you. I
» L I .
/!/ ` ~
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