Free Objections - District Court of Delaware - Delaware

Case 1 :04-cv—00874-GIVIS Document 150 Filed 04/03/2006 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
TELCORDIA TECHNOLOGIES, INC., )
Plaintiff, j
v. g Civil Action No. 04-874-GMS
ALCATEL USA, INC., l
Defendant. l
PLAINT IFF TELCORDIA TECHNOLOGIES, INC.’S
OBJECTIONS TO DEFENDANT ALCATEL USA, INC.’S
NOTICE OF DEPOSITION OF PIERRE ADAM
Plaintiff Telcordia Technologies Inc. ("Telcordia"), by its attorneys, hereby objects to
Defendant Alcatel USA, lnc.’s ("Alcatel") Notice of Deposition of Pierre Adam.
OBJECTION S
1. Telcordia objects to the time and location of the deposition. Telcordia will work
with Alcatel to schedule a properly noticed and properly conducted deposition at a mutually
agreeable time and place.
2. Telcordia objects to the extent the notice and deposition do not comply with Rules
28(b) and 29, Federal Rules of Civil Procedure, the Hague Convention, the laws of France, or the
laws regarding depositions conducted in France. For example, Alcatel’s March 6, 2006, notice
to take the deposition of Pierre Adam beginning at 9:00 am on April 7, 2006, on its face does not
appear to have properly notified all appropriate authorities of the deposition. Accordingly,
Telcordia does not agree to any deposition conducted in violation of applicable laws and
conventions.
3. Telcordia objects to the extent that Mr. Adam’s employer has not approved this
deposition, for example, by releasing Mr. Adam to divulge his employer’s confidential

Case 1 :04-cv—00874-GIVIS Document 150 Filed 04/03/2006 Page 2 of 4
information.
4. 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 Lucent and Cisco
(Telcordia Technologies, Inc. v. Lucent Technologies, Inc., Civil Action No. 04-875-GMS and
Telcordia Technologies, Inc. v. Cisco Systems, Inc., Civil Action No. 04-876-GMS).
5. Telcordia objects to the use of any documents at the deposition that have been
obtained by Alcatel, whether by subpoena to France Telecom or otherwise, that have not been
identified or provided to counsel for Telcordia by the close of business on March 31, 2006,
including documents bearing a production range of KKOOOOOI-KK00Ol21.
6. Telcordia objects to the extent that defendants Alcatel, Cisco, or Lucent have had
access to the noticed deponent prior to the deposition, such as through informal interviews in
which Telcordia was not present.
7. Telcordia objects to the late notice regarding contact information of the noticed
deponent.
8. Telcordia objects to the redaction of information in certain documents within the
production range of KKOOOOOI-KKO0Ol2l, because no basis has been provided for withholding
this information from Telcordia.
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Case 1 :04-cv—OO874-GIVIS Document 150 Filed O4/O3/2006 Page 3 of 4
ASHBY & GEDDES
/s/ TQ'72my Geyer Lydon
Steven J. Balick (I.D. #2114)
John G. Day (I.D. #2403)
Tiffany Geyer Lydon (LD. #3950)
222 Delaware Avenue, 17th Floor
P.O. Box 1150
Wilmington, Delaware 19899
(302) 654-1888
[email protected]
j [email protected]
[email protected]
Attorneys for Plaintw T elcordio Technologies, Inc.
Of Counsel:
Donald R. Dunner
Don O. Burley
Steven M. Anzalone
Richard H. Smith
Houtan K. Esfahani
FINNEGAN, HENDERSON, F ARABOW,
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 3, 2006
168245.1
3

Case 1 :04-cv—OO874-GIVIS Document 150 Filed 04/03/2006 Page 4 of 4
CERTIFICATE OF SERVICE
I hereby certify that on the 3rd day of April, 2006, the attached PLAINTIFF
TELCORDIA TECHNOLOGIES, INC.'S OBJECTIONS TO DEFENDAN T ALCATEL
USA, INC.'S NOTICE OF DEPOSITION OF PIERRE ADAM was served upon the below-
named counsel of record at the address and in the manner indicated:
J osy W. Ingersoll, Esquire HAND DELIVERY
Young Conaway Stargatt & Taylor, LLP
The Brandywine Building
1000 West Street
Wilmington, DE 19801
Stuart J. Sinder, Esquire VIA FEDERAL EXPRESS
Kenyon & Kenyon
One Broadway
New York, NY 10004
/s/ T Many Geyer Lydon
Tiffany Geyer Lydon
150908.1