Free Case Transferred In - District Transfer - District Court of California - California

Case 3:07-cv-04970-SI

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA GREENVILLE DIVISION Gregory P. Sloan, Plaintiff, vs. L.G. Philips LCD Co., Ltd., L. G. Philips LCD America, Inc., Samsung Electronics Co. Ltd., Samsung Electronics America, Inc., NEC Corp., NEC Display Solutions of America, Inc., NEC LCD Technologies, Ltd., NEC Electronics America, Inc., Sharp Corp., Sharp Electronics Corp., AU Optronics Corp., AU Optronics Corporation America, Chi Mei Optoelectronics Corp., Chi Mei Optoelectronics USA, Inc., International Display Technology Co., Ltd., International Display Technology USA, Inc., Hitachi Ltd., Hitachi America Ltd., Hitachi Electronic Devices (USA), Inc., Hitachi Displays, Ltd., Toshiba Corp., Toshiba Matsushita Display Technology Co., Ltd., Chunghwa Picture Tubes Ltd., Hannstar Display Corp., IDT International Ltd., Oregon Scientific, Inc., and Sanyo Epson Imaging Devices Corp. Defendants. ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ] ]

PLAINTIFF'S RESPONSES TO LOCAL RULE 26.01 INTERROGATORIES

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Case 3:07-cv-04970-SI

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Interrogatory: (A) State the full name, address, and telephone number of all persons or legal entities who may have a subrogation interest in each claim and state the basis and extent of said interest. Answer: None

Interrogatory: (B) As to each claim, state whether it should be tried jury or nonjury and why. Answer: All antitrust claims against Defendant are legal claims and should be tried by a Jury pursuant to the Plaintiff's Jury Trial Demand. Claims for unjust enrichment and injunctive relief are equitable and should be tried nonjury. Interrogatory: (C) State whether the party submitting these responses is a publicly owned company and separately identify: (1) each publicly owned company of which it is a parent, subsidiary, partner, or affiliate; (2) each publicly owned company which owns ten percent or more of the outstanding shares or other indicia of ownership of the party; and (3) each publicly owned company in which the party owns ten percent or more of the outstanding shares. Answer: Plaintiff is an Individual.

Interrogatory: (D) State the basis for asserting the claim in the division in which it was filed (or the basis of any challenge to the appropriateness of the division). Answer: A substantial portion of the events giving rise to this claim occurred in this division. Interrogatory: (E) Is this action related in whole or in part to any other matter filed in this District, whether civil or criminal? If so, provide: (1) a short caption and the full case number of the related action; (2) an explanation of how the matters 2

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are related; and (3) a statement of the status of the related action. Counsel should disclose any cases which may be related regardless of whether they are still pending. Whether cases are related such that they should be assigned to a single judge will be determined by the Clerk of Court based on a determination of whether the cases: arise from the same or identical transactions, happenings, or events; involve the identical parties or property; or for any other reason would entail substantial duplication of labor if heard by different judges. Answer: No related claims. However, the Judicial Panel on Multidistrict Litigation heard

a motion to consolidate similar cases. No ruling has been made on that motion. Dated: April 4, 2007 Strom Law Firm, LLC __s/ J. Preston Strom, Jr._________ J. Preston Strom, Jr. Fed. I.D. No. 4354 Mario A. Pacella Fed. I.D. No. 7538 2110 Beltline Boulevard, Suite A Columbia, SC 29204 Telephone: (803) 252-4800 Fax: (803) 252-4801 Gergel, Nickles & Solomon, P.A. Carl L. Solomon Post Office Box 1866 1519 Richland Street Columbia, South Carolina 29202 Telephone: (803) 779-8080 Whatley Drake & Kallas Joe R. Whatley, Jr. 1540 Broadway, 37th Floor 3

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New York, New York 35203 Telephone: (212) 447-7070

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