Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv—00875-GIVIS Document 99 Filed 02/27/2006 Page 1 of 1
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ATTORNEYS AND COUNSELLORS AT LAW TELEPHONE
302-654-IBBB
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February 27, 2006
The Honorable Gregory M. Sleet
United States District Court VIA ELECTRONIC FILING
844 North King Street
Wilmington, DE 19801
Re: T elcordia Technologies, Inc. v. Lucent Technologies, Inc.
C.A. No. 04-875-GMS
Dear Judge Sleet:
Telcordia has raised the following issues for presentation during the teleconference
scheduled for February 28, 2006 at 11:00 a.m.:
• In connection with Telcordia’s Third Notice of Rule 30(b)(6) Deposition that was served
on Lucent in December 2005, Telcordia respectfully requests an order requiring Lucent
to promptly designate and schedule appropriate Rule 30(b)(6) designee(s) to testify as to
subjects l0 through l2.
• Telcordia respectfully requests an order establishing rules and limits on the taking of
depositions and the use of depositions in this case, since Lucent and Telcordia have been
unable to reach an agreement.
Respectfully,
/s/ Steven J Balick
Steven J. Balick
SJ B/dmf
167054.1
c: John W. Shaw, Esquire (via electronic mail)
Steven C. Chemy, Esquire (via electronic mail)
David A. Nelson, Esquire (via electronic mail)
Donald R. Dunner, Esquire (via electronic mail)