Free Declaration - District Court of Delaware - Delaware

Case 1 :04-cv-01371-JJF Document 149 Filed 12/14/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
POWER INTEGRATIONS, INC., a Delaware
corporation, .
Plaintiff]
vi C.A. No. 04-1371
FAIRCHILD SEMICONDUCTOR
INTERNATIONAL, INC., a Delaware
corporation, and FAIRCHILD
SEMICONDUCTOR CORPORATION,
a Delaware corporation,
Defendants.
DECLARATION OF BAS DE BLANK IN SUPPORT OF
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S MOTION
T0 COMPEL DAMAGES DISCOVERY
I, Bas de Blank, the undersigned, declare as follows:
1. I am an attomey with the tinn of Orrick, Herrington & Sutcliffe LLP, counsel of
record for Defendants Fairchild Semiconductor Intemational, Inc. and Fairchild Semiconductor
Corp. (collectively, "Fairchild”). I am admitted to the Bar of the State of California I make this
declaration in support of Defendants’ Motion to Amend the Schedule. I make this declaration of
my own personal knowledge and, if called as a witness, I could and would testify competently to
the truth of the matters set forth herein.
2. Attached hereto as Exhibit A is a true and correct copy of a letter from Bas de
Blank to Howard G. Pollack dated February 3, 2005.
3. Attached hereto as Exhibit B is a tmc and correct copy of a letter from Bas de
Blank to Michael Headley dated December 5, 2005.
4. Attached hereto as Exhibit C is a true and correct copy of a letter from Michael R.
Headley to Bas de Blank dated December 5, 2005.
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Case 1 :04-cv-01371-JJF Document 149 Filed 12/14/2005 Page 2 of 2
5. Attached hereto as Exhibit D is a true and correct copy of a letter from Bas de
Blank to Michael Headley dated December 6, 2005.
6. Attached hereto as Exhibit E is a true and correct copy of a letter from Michael R.
Headley to Bas de Blank dated December 6, 2005.
7. Attached hereto as Exhibit E is a true and correct copy of a letter from Michael R.
Headley to Bas de Blank dated December 6, 2005.
8. Attached hereto as Exhibit F is a true and correct copy of a letter from Bas de
Blank to Howard G. Pollack dated December 8, 2005.
9. Attached hereto as Exhibit G is a true and correct copy of an electronic message
from Michael Headley to Bas de Blank dated December 8, 2005.
10. Attached hereto as Exhibit H is a true and correct copy of a letter from Bas de
Blank to Howard G. Pollack dated September 28, 2005.
11. Attached hereto as Exhibit I is a true and correct copy of a letter from Bas de
Blank to Gina M. Steele dated October 28, 2005.
I declare the foregoing is true and correct under penalty of perjury under the laws of the
United States of America.
Executed on December 14, 2005 in Menlo Park, California.
Bas de Blank
ORRICK, HERRINGTON & SUTCLIFFE LLP
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