Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv-01338-JJF Document 998 Filed 04/17/2008 Page 1 of 2
BLANK — RO/vilirrr
counseiorts AT rww
Phone: (302) 425-64I0
Fax: (302) 428-5132
Email: P0ggitig¢DBlankR0me·.cam
April 17, 2008
Thomas C. Grimm, Esquire Richard Horwitz, Esquire
Morris Nichols Arsht & Tumtell LLP Potter Anderson & Corroon LLP
1201 North Market Street 1313 North Market Street
Wilmington, DE 19801 P.O. Box 951
Wilmington, DE 19801
Amy Elizabeth Evans, Esquire Frederick L. Cottrell, III, Esquire
Cross & Simon LLC Richards Layton & Finger
913 North Market Street One Rodney Square
11th Floor 920 N. King Street
Wilmington, DE 19801 Wilmington, DE 19801
Robert J. Katzenstein, Esquire Arthur G. Comtolly, III, Esquire
Smith Katzenstein & Furlow LLP Connolly Bove Lodge & Hutz LLP
800 Delaware Avenue, Suite 1000 1007 North Orange Street
Wilmington, DE 19801 Wilmington, DE 19801
John W. Shaw, Esquire Matthew Neiderman, Esquire
Young Conaway Stargatt & Taylor LLP Duane Morris LLP
1000 West Street, 17°h Floor 1100 North Market Street, Suite 1200
Wilmington, DE 19801 Wilmington, DE 19801
David J. Margules, Esquire
Bouchard Margules & Friedlander, P.A.
222 Delaware Avenue, Suite 1400
Wilmington, DE 19801
Re: Honeywell International Inc. et al. v. Apple Computer Inc. et al.
C.A. N0. 1:04-cv-01338-JJF
Dear Counsel:
Consistent with Judge Faman’s direction to me, please be advised that I informed his
Honor on April 16, 2008 that my firm is adverse to Dell Inc. in a matter presently pending in the
Eastern District of Texas, Tyler Division, involving different patents. I also advised him that my
firm is also representing Honeywell International Inc. in multi-defendant asbestos tort related
actions presently pending in Western and Southwestern State County Courts in Ohio —
Honeywell is not considered to be a primary defendant.
Chase Manhattan Centre 1201 Market Street Suite 800 Wilmington, DE 19801
www.Blanl 900200.0000l/40l74328v.1
Delaware • Florida • New lersey ~ New York • Ohio • Pennsylvania • Washington, DC • l-long Kong

Case 1:O4—cv—O1338-JJF Document 998 Filed O4/17/2008 Page 2 of 2
BLANK ~ ROMELLP
All €¤¤¤S€1 COUNSHORS AT aw
April 17, 2008
Page 2
I told Judge Farnan, with respect to same, that no work is being accomplished out of my
Firm’s Wilmington office and that I have not had, nor will I have, any involvement with either
matter.
If counsel deems it necessary, my Firm is prepared to establish a timely and effective
screening procedure prior to the time I begin work as Special Master to ensure that, through a
"cone of silence," no confidential information that may come into my possession will be shared
with those involved in the referenced matters and that I am not informed in any way of the status
of or facts relating to these matters.
I also asserted respectfully to the Court that I was satisfied I would be able to discharge
the responsibilities of a Special Master in a fair and impartial manner and that I did not believe
that my ability to do so might reasonably be questioned in light of the above information.
As I would like to establish a date for an initial conference in the matter, please advise
my secretary of all available dates for the week of April 21, 2008 for a conference to be held in
the J. Caleb Boggs Federal Building, unless counsel agree that a teleconference would be more
convenient. I expect we should be able to conclude our business within a two hour time frame.
I, of course, am prepared to discuss the subject of this letter during the conference or earlier if
counsel believe it necessary.
urs very 1
Vincent J. P 1ti
Specia aster (DE # 100614)
VJP/mcm
cc: The Honorable Joseph J. Farnan (via hand delivery)
90020000001/40174328v. 1