Free Objections - District Court of Delaware - Delaware

Case 1 :04-cv—00875-GIVIS Document 132 Filed 04/06/2006 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
TELCORDIA TECHNOLOGIES, INC., )
)
Plaintiff, )
)
v. )
) Civil Action No. 04-875-GMS
LUCENT TECHNOLOGIES INC., )
)
Defendant. )
PLAIN TIFF TELCORDIA TECHNOLOGIES, INC.’S
OBJECTIONS TO DEFENDAN T LUCENT TECHNOLOGIES INC.’S
NOTICE OF DEPOSITION OF STEVEN J OROFF
Plaintiff Telcordia Technologies, Inc. ("Te1cordia"), by its attorneys, hereby objects to
Defendant Lucent Technologies Inc.’s ("Lucent") Notice of Deposition of Steven Joroff.
OBJECTIONS
l. Telcordia objects to the time and location of the deposition. Telcordia will work
with Lucent to schedule the deposition at a mutually agreeable time and place.
2. Telcordia objects to the use, including use by other parties, of any testimony from
the noticed deposition in separate cases, such as the pending suits against Alcatel and Cisco
(Telcordia Technologies, Inc. v. Alcatel USA, Inc. Civil Action No. O4-874-GMS and Telcordia
Technologies, Inc. v. Cisco Systems, Inc., Civil Action No. 04-876-GMS).
3. Telcordia objects to the extent that this deposition in combination with
depositions of other witnesses would cause Lucent to exceed any of the limits on depositions set
forth in the Federal Rules of Civil Procedure.
4. Telcordia objects to the extent that this deposition seeks information that is
protected by claims of attorney-client privilege or attorney work product in light of the fact that

Case 1 :04-cv—00875-GIVIS Document 132 Filed 04/06/2006 Page 2 of 4
Steven J orofti as part of his duties at Telcordia, had significant contacts with Telcordia’s lawyers
and was extensively exposed to confidential and privileged information.
5. Telcordia objects to the extent that Lucent seeks to depose Mr. J orofi who was
extensively involved in privileged attomey/client communications as part of his regular job
duties at Telcordia, without pennitting Telcordia to confidentially confer with Mr. J oroff to
ensure that no disclosure of proprietary or privileged Telcordia information occurs.
6. Telcordia objects to an impermissible conflict of interest that would be created if
Lucent and its lawyers, who are directly adverse to Telcordia in this litigation, attempt to
represent or speak on behalf of Lucent’s current employee, Mr. J oroffQ concerning any matter
relating to his prior work for Telcordia.
7. Telcordia objects to this deposition as unreasonably broad, burdensome, unfair,
and harassing to the extent that Lucent seeks to encourage or pressure its current employee, Mr. .
J oroff, to disclose privileged, proprietary, or private information of Telcordia in violation of Mr.
J oroff s employee agreement with Telcordia or his ethical obligations.
ASHBY & GEDDES
/s/ T yjimy Geyer Lydon
Steven J. Balick (1.D. #2114)
John G. Day (I.D. #2403)
Tiffany Geyer Lydon (I.D. #3 950)
222 Delaware Avenue, 17th Floor
P.O. Box 1 150
Wilmington, Delaware 19899
(302) 654-1888
[email protected]
j [email protected]
[email protected]
Attorneys for Plaintgyf T elcordia Technologies, Inc.
2

Case 1 :04-cv—00875-GIVIS Document 132 Filed 04/06/2006 Page 3 of 4
Of Counsel:
Donald R. Dunner
Don O. Burley
Steven M. Anzalone
Richard H. Smith
Houtan K. Esfahani
FINNEGAN, HENDERSON, FARABOW,
GARRETT & DUNNER, L.L.P.
901 New York Ave., N.W.
Washington, D.C. 20001
(202) 408-4000
York M. Faulkner
FINNEGAN, HENDERSON, FARABOW,
GARRETT & DUNNER
Two Freedom Square
11955 Freedom Drive
Reston, VA 20190
(571) 203-2700
Dated: April 6, 2006
168349.1
3

Case 1 :04-cv—00875-GIVIS Document 132 Filed 04/06/2006 Page 4 of 4
CERTIFICATE OF SERVICE
I hereby certify that on the 6th day of April, 2006, the attached PLAIN TIFF
TELCORDIA TECHNOLOGIES, INC.’S OBJECTIONS TO DEFENDAN T LUCENT
TECHNOLOGIES INC.’S NOTICE OF DEPOSITION OF STEVEN J OROFF was sewed
upon the below-named counsel of record at the address and in the manner indicated:
John W. Shaw, Esquire I-LAND DELIVERY
Young Conaway Stargatt & Taylor, LLP
The Brandywine Building
1000 West Street
Wilmington, DE 19801
Steven C. Cherny, Esquire VIA FEDERAL EXPRESS
Latham & Watkins LLP
885 Third Avenue, Suite 1000
New York, NY 10022
David A. Nelson, Esquire VIA FEDERAL EXPRESS
Latham & Watkins LLP
Sears Tower, Suite 5800
Chicago, IL 60606
/s/ T yjimy Geyer Lydon
Tiffany Geyer Lydon
150909.1