Free Opening Brief in Support - District Court of Delaware - Delaware

Case1:04-cv-00876-GIVIS D0cument217-2 Filed 08/11/2006 Page1 0f3
Exhibit A

Case 1 :04-cv—00876-GIVIS Document 217-2 Filed 08/11/2006 Page 2 oP3ge l of2
Williamson, John
From: Dunner, Don
Sent: Tuesday, July 25, 2006 3:00 PM
To: '[email protected]'
Cc: [email protected]; [email protected]; Williamson, John; [email protected];
Sonal.l\/|[email protected]
Subject: RE: Experts
Ed:
Your proposal to have Dr. Acampora file a reply validity report on the ’633 patent is unacceptable to Telcordia,
Dr. Jones filed the opening report on behalf of all defendants and it is therefore too late to offer a new expert on
this subject, particularly after Telcordia has already submitted its answering report on this very issue.
Don
From: [email protected] [[email protected]]
Sent: Tuesday, July 25, 2006 1:10 PM
To: Dunner, Don
Cc: [email protected]; [email protected]; Williamson, John; [email protected];
[email protected]
Subject: Experts
Don:
Confirming our discussion at your request:
l informed you that we plan to have Dr. Acampora adopt the Jones opening report on the '633 Patent and
also submit any reply in further support. The reason is as follows. The defendants have bent over
backwards to avoid submitting multiple briefs, letters, and expert reports on the issues in this case. As
part of that effort, the defendants submitted a '633 Report from Jones to accommodate Alcatel, who has
used him in the past. Now that Alcatel's case is stayed, Cisco and Lucent will use instead their preferred
expert, Dr. Acampora.
Regarding depositions, we propose two days of expert deposition for each witness. For Dr. Acampora, we
would make him available for a third day if you thought you needed that.
Best,
Ed
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