Free Response in Opposition to Motion - District Court of California - California

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 1 of 22

Exhibit 1

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 2 of 22

Kramer Law Offce, Inc.
9930 Mesa Rim Rd.. Ste. 160
San Dieo. Cafifamla 92121

Phone 858/362-3 J 50
fax 858/824-9073

Melody A. Kramer, Esq.
mak~lcamer1awp.com

VIA FAX and FEDERA EXPRESS
May 6, 2008
Roger G. Perkins, Esq

Angela Kim, Esq.

MORRS POLICH & PURY LLP
501 West Broadway, Suite 500 San Diego, Californa 92101
Facsimile: (619) 557-0460
Orlando F. Cabanday

Robert S. Mallin Brinks Hofer Gils9n & Lione NBC Tower 455 N City Front Plaza Drive Suite 3600
Chicago, IL 6061 1

Facsimile: (312) 321-4299

HENNLLY & GROSSFELD LLP 4640 Admiralty Way, Suite 850
Marna del Rey, CA 90292

Facsimile: (310) 305-2116

RE: Sorensen Researh & Development Trut v. Emerson Electrc. et al
USDC Southern Distrct of Californa, Case No. 08cv00060 Sorensen Research & Development Trut v. Ryobi Tecliologies. et al USDC Southern Distrct of Californa, Case No. 08cv00070 Sorensen Research & Development Trut v. Senco Products. Inc.. et al USDC Southern Distrct of Californa, Case No. 08cv00071
Request for agreement to conduct lited discovery durng stay for the purose of

preserving evidence
Dear Messrs. Malli, Perkins and Cabanday:

In accordance with the Order for stay by Judge Moskowitz in the above cases, we are hereby requesting the Defendants' agreement to preserve certain items of evidence to ensure that they wil not be lost durng the time that this case is being stayed. If we are unable to reach an agreement, we wil be asking the Cour for an order to produce this
evidence.

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 3 of 22

1. All prototye and production molds used'

in the production of the Accused

Products that are curently in the possession. or control of either

Defendants or non-pares; and
2. All design and. techncal DocUIents for the Accused Product that are in

the possession or control of either Defendants or non-paries. .
3. Intial disclosures puruant to Rule 26(a)(1), specifically including the

products at issue. .
Sorensen Research & Develoomeit Trust v. Emerson Electrc. et al
Ridgid 18V Cordless Reciprocating Saw Ridgid HD 3/8" VSR Drill
. Ridgid lI Reciprocating Saw

identity and location of all manufactuers, suppliers, and importers for the

The products at issue at this point include the following identified products, and any other products made with the same molds or similar manufactung process:

Ridgid Heavy Duty VSR Dryall
Screwdrver
. Ridgid Professional 3/8" VSR Drill

Ridgid 18V Cordless Yi" Hamer Drill Ridgd 18V Cordless 1/2" Drill Ridgid 18V Cordless Drill
Ridgid 14.4V Cordless.Yi" Drill
Ridgid 12V Right Angle Impact Driver
Ridgid 14.4V Impact Driver
Ridgid 12V Cordless 3/8"Drill

Ridgid Heavy Duty Yi" VSR Hamer
Drill Ridgid Max Select Dual Voltage Jig Saw Ridgid Heavy Duty Yi" VSR Drill Ridgid 12 Volt Cordless 3/8" Drill Ridgid Max Select Dual Voltage Reciprocating Saw
Ridgid 18 Volt Compact Lithium - Ion

Ridgid Heavy Duty 3 Speed Yi" Right

Angle Drill Ridgid Heavy Duty 2 Speed Yi" VSR Drill Ridgid Heavy Duty VSR DrYall

Drill Ridgid Max Select Dual Voltage Circular Saw
Ridgid 24 Volt Lithum-Ion Cordless

Screwdrver
Ridgid Heavy Duty Yi" VSR

Hamer Drill
Ridgid Worklight
Ridgid Y4 Sheet Sander

Hamer/Pulse Drill Ridgid 7 W' Worm Drive Saw
Ridgid Heavy Duty 7 W' Cirular Saw Ridgid 18V Cordless Jig Saw Ridgid Varable Speed Orbital Jig Saw Ridgid Heavy Duty l1A Reciprocating Saw Ridgid 18V Cordless Hand Planer Ridgid Heavy Duty Varable Speed Belt Sander Ridgid 9.6V Pivoting Screwdrver Ridgid 9.6V Pivoting Screwdrver
Ridgid Heavy Duty Yi" Two Speed

Ridgid 5" Random Orit Sander Ridgid Max Select Hand Planer
Ridgid 6 Yz" Compact Framing Saw
Ridgid 12

Volt Right Angle Impact Driver

Ridgid 7" Circular Saw
Ridgid 7 Y4" Worm Drive Circular Saw

. Ridgid Varable Speed Orbital Jig Saw Ridgid Yi" Right Angle Drll
Ridgid Varable Speed Belt Sander

Ridgid Twist Handle Orbital
Reciprocatig Saw
Ridgid Heavy Duty I

Hamer Drill

. Saw

lAmp Reciprocating

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 4 of 22

Ridgid 18 Volt Cordless Impact Driver Ridgid 1 8 Volt Reciprocating Saw

Ridgid 18 Volt Circular Saw Ridgid I 8 Volt Cordless Hamer Drill

Sorensen Research & Development Trust v. Rvobi Technoloires.et al
Ryobi 18.0V Circular Saw

Ryobi 13 AM Circular Saw
Ryobi 14.4V Drll

Ryobi 18" Electrc Chainsaw Ryobi One+ Lithium 1 8V Circular Saw
Ryobi One+ Lithum 18V Reciprocatig

Ryobi i 8.0V DrilVDriver
Ryobi 14.4V Drilllriver

Saw
Ryobi One+ Lithum 18V Drlllriver

Ryobi Hamer Drill
Senco Collated Screw Driver
It is our understading that manufactug'

Ryobi One+Lithium 18V Flashlight

Sorenen Research & Development Trust v. Senco Products. Inc.. et al

of

the Accused Products has been'done

in Chia by undentified com¡niny or companes, not by the Defendants. As such, and

because we are also aware of often complicated sometimes international, chain of
company ownership, there is simply no assurance that ths nec~ssar techncal

inormation will be available to my client once the stay is lifted. Furermore, as we
alreay pointed out to you, failure to identify manufctuers, suppliers, and importers will make it impossible for us to assure that all evidence is preserved.

Please advise us no later than May 27tJ if your clients are willing to stpulate to . ths limited discovery durng' the stay, otherwse we will file a motion with the Coli.
Additionally, please advise us by May 27th if DefendaIts have any categories of'

evidence that they want to ensure are presered. Although we are cognant of our
general obligation to preserve evidence, we are willng to work with you to ensure that any parcular categories of evidence that you thnk may be necessar when stay is lifted,
are adequately preserved.
Than you for your attention to ths matter.

dì

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 5 of 22

Exhibit 2

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 6 of 22

BRINKS
Robert S. Malln
312.321-4221

rmalJn~usebrinks.com

HOFER GilSON &1I0NEf)
A Prll-ll Corp..

May 27, 2008

IntiUectlQ1 Prpert
Law Worldwide

Via Facsimile Transmission to 858-824-9073 And US. First Class Mail

Melody A. Kramer, Esq.
Kramer Law Offce

9930 Mesa Rim Road
.Suite i 600 San Diego, CA 92 i 21
Re: Sorensen v. Emerson et al.

Case No. 08-CV-0060-BTM-CAB
Dear Melody:

I wrte in response to your letter dated May 6, 2008. Please be advised that Emerson Electrc Co.; Ridge Tool Company; One World Technologies, Inc.; and Ridgid Inc. will comply with their preservation requirements in accordance with the, Federal Rules of Civil Procedure and
applicable case law.
,

As for your offer to consider what categories of evidence to preserve, I assue that you wil also
abide by the requirements of the Federal Rules of

Civil Procedure and applicable case law.

I trust that this letter resolves the issue. If you have any fuer concerns, feel free to contact me.

i;~
Robert S. Mallin
RSM:jms
cc: Roger G. Perkins, Esq.

:.1

Angela Kim, Esq.

NBC Tower. Suit. 3600 I 455 N. Cilyront Plaza Drie I Chicago, IL 60611-5599 I T.raphone 312.321.4200 I Fax 312.321.4299 I us.biinks.com

- -_....__...:.- -_._...__:_~._-,--______..__ --___. ____w_~_:__,.._ .___._-:_ :.:.___,__~..._._._..__:.__.___~~...:_.~_.~. __~.._._.._._______.______~______

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 7 of 22

Exhibit 3

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 8 of 22

Kramer Law Offce, Inc.
9930 Mesa Rim Rd.. Sfe. 160
San DIego. corifomia 92121

Phone 85/362-3150
fax 858/824-9073

Melody A. Kramer, Esq.
mak~l:amer1awp.com

VIA FAX and

FEDERA EXPRESS
June 3, 2008

Robert S. Malln
Bri Hofer Gilson &. Lione

NBC Tower 455 N City Front Plaza Drive Suite 3600 Chicago, IL 6061 I Facsimile: (312) 321-4299

RE: Sorensen Research & Development Trust v. Emerson Electrc. et al USDC Southein Distrct of Californa, Case No. 08cvO0060 Sorensen Research & Development Trut v. Rvobi Technologies. et al USDC Southern Distrct of Californa, Case No. 08cv00070
Sorensen Reseach & Development Trust v. Senco Products. Inc.. et al
USDC Southern Distrct of

Californa, Case No. 08cv00071

Request for agreement to conduct'limited discovery durg stay for the pwpose of

preservng evidence .

Dea Mr. Malln:
Than you for your letters dated May 27th regarding the above-captioned cases

stay in this case. I need to have some additional clarfication to ensure that necessar evidence is being preserved. ,
products in these cases are manufactued by companes that are not located inthe accused the United
States and that are several levels of corporate Strctue away from the defendants in this case or by thrd-pares that are contrcted by several levels of companes away. As such, We are aware from prior corrspondence and investigation that all of

and my request for preseration of evidence pending lift of

assurng us that the named paries "will comply with their preservation requirements in the Federal Rules of Civil Procedure and applicable case law" really doesn't mea anyting.
acordance with

.,)

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 9 of 22

Are all prototype and production molds

used in the production of

Products being preserved? Are all design and ttchncal documents for the Accused

the Accused

Products being preserved?

adequate assurances of

Please clarfy this matter for me no later than June 13th. Ifwe do not receive where ths highly relevant evidence is being held and what steps

ar being taen to preserve it, we will have no choice but to procee to the Cour. Be advised that Judge Moskowitz has already heard one motion for exception to stay for
preservation of evidence and did order certn discovery to proceed. A copy of that

ruling is enclosed with this letter.

enclosure

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 10 of 22

C se 3:06-cv-0 1572-BTM-CAB Document 277 Filed 06/03/2008 Page 1 of 2

1

2
3

4
5
6

7
8

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF CALIFORNIA
JENS ERIK SORENSEN,
Plaintiff,

9

10
11

CASE NO. 06CV1572 BTM (CAB)
ORDER GRANTING IN PART AND DENYING IN PART MOTION FOR EXCEPTION TO STAY; GRANTING, IN PART AND DENYING IN PART ' MOTION TO FILE DOCUMENTS UNDER SEAL; AND GRANTING REQUEST FOR ORAL ARGUMENT

12

vs.
BLACK & DECKER CORPORATION,

,13
14

15 16
17 18

or e reasons se 0 on e record, the Court GRANTS IN PART AND DENIES

Defendant.

IN PART Plaintiffs motion for exception to stay (Doc. 264). Plaintiff may take limited
depositions of the relevant entities as set forth on the record~ Plaintiff may also

undertake an inspection

attempt to of the out-of-district manufacturing facility through appropriate

19

procedural avenues. Plaintiffs request for discovery as to the alleged UK facilty is denied

20 without prejudice. The Court also GRANTS IN PART AND DENIES IN PART Plaintiffs
21

motion to file documents under seal (Doc. 265, 271). Defendants shall file a publicly available

22 version of the documents which the Court ruled should not be sealed within one week of the
23
date of this order. The request for oral argument is GRANTED (Doc. 266).
IT IS SO ORDERED.

24
25 26

DATED: June 3, 2008

27
28
\;

Honorable Barr Ted Moskowitz

United States District Judge

~~
1

06CV1572 BTM (CAB)

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 11 of 22

se 3:06-cY.;01572-BTM-CAB Document 277 Filed 06/03/2008 Page 2 of 2

1

2
3

4
5
6

7

8
9

10
11

12

13
14 15

16

17
18

19

20
21

22
23
24

25
26

27 28

2

06CY1572 BTM (CAB)

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 12 of 22

Exhibit 4

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 13 of 22

Robert S. Malln
312;321-4221

BRINKS

rm8IJn~usebrinks.com

June 6, 2008

HOFER GilSON
& 1I ON E
~
A Prl.uf...i Corpon

Via Facsimile Transmission to 858-824-9073

And US. First Class Mail
Melody A. Kramer,Esq. Krer Law Offce

Intolleduil Piciert
Law Worlwie

9930 Mesa Rim Road Suite 1600
San Diego, CA 92 i 2 i
Re: Sorensen v. Emerson et al.

Case No. 08-CV-0060-BTM-CAB
Dear Melody:

I write in response to your letter dated June 3, 2008. Before I can respond to the requests made in that June 3 letter, I need some clarfication regarding what things and information you are
seekig to have preserved. Indeed, if third paries are going to commit to preserve information

what is included. Accordingly, please identify and explain to me what you mean by the phrases:
and things, we need to have a clear understading of

I. "All prototyp and production molds used in the production of the Accused

Products. "
2. "All design and technical documents for the Accused Products".

I expect that your identification of information and thngs wil be with specificity and your explanation will be clea and concise so that both we and any thrd pares will understad the
scope of the request. Afer 1 receive your response, I will be in a better position to fuly respond

to your inquiry.

Robert S. Mallin
RSM:jms

4i~
Angela Kim, Esq.

cc: Roger G. Perkins, Esq.

NBC Tower. Suite 3600 I 455 N. Cityont Pl Drive I Chicago, IL 60ell.5599 I relephone 312.321.4200 I Fax 312.321.4299 I usebrinks.com

- -' _...._.... -_..- ,._- _.:.. --,._-_._-.__. -- . -, . . ..__.__:. -...'._--------------,-------- _.._-.._...._-_..._-- -_.__........_._._----- - .....__._-_. .._._~--_._~._._---_..--'--~-_.._----~.-=.........;.:.__.:_-"..__...- ..._- _..__.__.__._--------_..-

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 14 of 22

Exhibit 5

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 15 of 22

= ((py

~
~

TTI

/-Techtronic Industries North America,lnc.
Wrier's Dire Dial: 864.9643308 Writer's Dire Fax: 864.963350

July 10, 2006 Via U.S. Mail

Wrier's Emai/: bob.bugosC§ttigroupna.com

Melody l\. Kramer, Esq.
Krer Law Offce

9930 Mesa Ri Rd., Ste 1600 San Diego, Calorna 92121
Dear Ms. Krer:
Ou part company's legal dearent in Hong Kong has confed tht the procss

they use for over-moldig plascs inyolves moVU the par from one mold to the next
constue an ingement of your client's U.S. Pat No. 4,935,184, I believe we have
completely rued out the issue by vie of

entily by had, without use of any mechaca mea to trrt them. Without sugestg any valdity to the idea that mechacay trportg the par would
the method they use.'

You have requested an afdavit frm someone locate in the United States. As you
know, ths is complicated by the fac tht the people who ar in the best position to give
such an afdavit ar locatd in Hong Kong. We could dr an afdavit cerg tht

we have contated our parnt company, and tht we are confdent the inormation we

have received is acumte, if you conf that ths will close the issue.
Regards,

i.
1 i!

Robert A. Bugos

Genera Counel

Techtronic Industries North America, Inc. 1428 Peannan Dairy Road, Anderson SC, USA

Tel 864.226.6511 1.800.323.4615 ww.ttgroup.com

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 16 of 22

Exhibit 6

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 17 of 22

BRINKS
Robert S. Mal/n
312'321-4221

rmallin(!usebrinks.com

HOFER GilSON

A_~
November 30,2007

&ll 0 N E

~

Intellecl ~pe
Liw Woitirde

Via Facsimile Transmission to 858-824-9073

And Us. First Class Mail

Melody A. Krer, Esq.

Kramer Law Offce, Inc. 9930 Mesa Rim Rd.
Suite 1600 '

San Diego, CA 92121
Re: Sorensen Research & Development Trust v.

Ryobi, Senco, One World, Techtronics, et aL
U.S. Patent No. 4,935,184

Dea Melody:

I wrte in response to your letters dated November 8, 2007 and November 19, 2007 identifying
products that you believe are

manufactued using a process covered by your client's U.S.' Patent

No. 4,935,184, and seeking inormation about the source of

those products.

your letters are manufactu by or for ITI in Chia. In your November 19 letter, you make
reference that Ridgid brad products "are represented as being manufactued

As you have been advised several times in the past, Techtronic Industres Ltd Co. (''II'') is the parent corporation for Ryobi Technologies, Inc; One World Technologies; Inc.; and Techtronic Industries Nort America, Inc. ITI is located in Hong Kong and all of the products identified in

by (One World Technology, Inc.) in their manuas." In a conversation, you specifically mentioned that you were looking at the manua for the R3000 reciprocating SaW. As an intial matter, I note that the box for the R3000 clearly indicates that it is "Made in Chia". The reference in the manual that you refer to is in the "Waranty" section and is intended to identify a company to reach in case of waranty issues.

Additionally, as you have been advised, the ovennold injection process used for the extema housings for all of those products, including but not limited to the external housings for Ridgid brand model no. R7000 drll shown in drawing number D-541 1, the Ryobi brand model no. R1063K circular saw shown in drawig number D-5398, and the Senco brad model no. DS200AC collated screw driver shown in drawig number D-5506 (all thee drawings atthed hereto at Ex. I), is as follows:

NBC

Tower . Su~e 3600 I 4eiei N. Cinl Plaz Drie I Chicgo, IL e0611.ei599 I Telephone 312.321.4200 ¡ Fax 312.321.4299 I usbñnksco

-- ---..--------- -----.---- ----.-.--.. _..._.... . ._.... . ..--,-----. .-." -.._.._---_.-, -,--- "_.'.'-.-------'--- ---.- .._._____~__.____,____,___ _____. __~_.____._ -1_------- __._,~_.______,_._.______

.... '. .

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 18 of 22

Melody A. Krer, Esq.

November 30, 2007
Page 2

1) The first plastic material component 20 (with reference to Ex. 1) is injected into a first mold to get/form the plasic par which can be described as being the substate
parsupporting par.
2) The supporting par is transferred by had to a second, separte mold and then
sècond plastic material

component 32 (with reference to Ex. I) is injected into the second

mold to cover the substrte parsupportng par and get the housing' shown in the

drawigs atthed at Ex. 1.

I fuer note that in your letter you dispute that the ITI overmolded par shown in the drwings ar manufactued using two separate molds and that you "know ths is not the case." Wht is the basis for your knowledge that "this is not the cae?" Additionally, you mention.tht Mr. Bugos testified under oath that he does not know who manufactus .the tools identified in your letter.
Can you identify and pJ:ovide me with that testimony?

In the past, we have discussed providing a dechiration from someone at ITI in Hong Kong or China because that person would have the most knowledge and is best capable to describe the process due to their proximity and/or direct involvement with the process. You. rejected our proposa and told me that such a declartion would not be sufcient. Your basis was that declarations from 'persons in Hong Kong 'and Chia would not be ad1issible and could not be used in U.S. Distrct Cour because they are not subject to the penalty of perjur. Y oualso took the position durng a cònversaon relatig to ths issue that persons from Hong Kong and China could not testify in U.S. Cour. In your letter dated November 8, you cited United Stales v. Oudevenko,2001 WL 253027 (B.D. N.Y. Mar. 7, 2001)to support your position. That case however, is not on point or even applicable here. In Oudevenk, the defendant wanted to use depositions as a substitute for testmony at a crimina tral. The cour held tht the defendant did
not meet the "exceptional circumstaces" requiement of Crimial Procedure. The Rules of Rule 15(a) of the Federa Rules of Crimin Procedure have nothng to do with tlssitution and

have no bearng on a civil proceeding.

Contrar to your position that declarations from persons located in Hong Kong or China are.not admssible in U.S. cour, 28 USC § 1746 speifically provides for the use of declarations executed outside the United States. Pursuat to 28 USC § 1746, cour do and have accepted declarations from persons located in both Hong Kong and China. For example, in Commodity Futures Trading Comm 'n v. Topworih Intl Lid, 205 F.3d 1107, 1112 (9th Cir. 2000), the district cour rejected a declaration from Mr. Yu from Hong Kong because it allegedly did not meet the requirements of28 USC § 1746. The Ninth Circuit held that that the distrct cour's rejection
was improper as it did comply with § 1746, and made Mr. Yu's declartion par of

the record.

Likewise, in American Home Assurance Co. v. Zim Jamaica, 296 F. Supp.2d 494, 496-99 and ((S.D.N.Y. 2003), the cour accepted declarations from Assad Najm, the manager ofa company
\ì

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 19 of 22

Melody A. Kramer, Esq. November 30, 2007
Page 3

in Guangzou, Chia and Lao Xiji,

a trck drver who delivered cargo from Guangzhou to the

Port of China as par of a motion for sumar judgment.
You also advised me that it is improper for the U.S. subsidiares to rely upon their parnt
corpration for information. You rely on Minnesota Mining & Mfg. Co. v. Johnson & Johnson

Orthopedics, Inc., 976 F.2d 1559, 1580-81 (Fed. C.ir. 1992) and NTP, Inc. v. Research In Motion, Lid, 270 F. Supp.2d 751, 756-57 (E.D.Va. 2003) to support your position. Those caes do not
support your position and in fact have

no bearng on whether a subsidiar ca rely on

infonnation, it receives from' its parent corpration. Instead, those cases relate to the issue of
willful inngement, the duty of due care and whether aì opinion of counel is competent under

the circumstces. As I advied you, the Federal Circuit abolished the duty of due car in In re
Seagate, 497 F.3d 1360 (Fed. Cir. 2007), which makes these cases parcularly irelevant.

Please let me know if you have any questions about the above inonnation so that we ca moye towad finally resolving this matter..

Robert S. Mallin RSM:jms Encs.

-

/'

------~---_.__.._-..;:---- .._----------------- ."--"._--'-----'.- - -- ...-

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 20 of 22

, --, 'r-- ¡
iii

ltIc! f

I

'ii ,i i ¡

iHJ¡

!

/
I ~

j

(!
,'.,..,\

III

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 21 of 22

. "~T;j.k~""" '

...~--..-

.-

----

ml ~J.¡ ij
i I ¡ :

lilll ¡

! i

I

.\ (,

'~ l. ~
I

Cf

o

10 l.

.. S .. o o

Id
"'

~,

'-\

Ii
/'"" ( )
i

L

, ._._J

Case 3:08-cv-00060-BTM-CAB

Document 43-3

Filed 08/06/2008

Page 22 of 22

_.

.._...~.~
....._._-,

r
i i , ¡ i ! i

1

I-T; ,

:j¡~
: J! ¡ i!
í I

:.it

, (/ ¡~
i

a:

lt ::
o
);: :~
1 j

i .. i :i

'0

o a:
! i I

o o .. a:

Q

C)

i

\1

I i

l_

'~'Ili