Free Declaration - District Court of Delaware - Delaware

Case 1 :04-cv-00343-JJF Document 680 Filed 05/29/2007 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
L.G. PHILLIPS LCD CO., LTD.,
Plaintiff, Civil Action No. 04-343-] JF
TATUNG COMPANY; TATUNG
COMPANY OF AMERICA, INC.; AND
VIEWSONIC CORPORATION,
Defendants
DECLARATION OF VALERIE W. HO
I, Valerie W. Ho, declare:
1. I am a shareholder of Greenberg Traurig, LLP, one of the law firms
representing Tattmg Company and Tatung Company of America. I have been admitted
pro hac vice in connection with this case. I have personal knowledge ofthe matters set
forth below, and if called as a witness, could and would competently testify regarding
these matters. I make this Declaration in support of the Tatung Defendants’ Objections
to the Special Master’s Report and Recommendation Regarding (a) LG. Philips LCD Co.,
Ltd.’s ("LPL") Motion to Compel Tatung Defendants to Provide Discovery on Advice of
Cotmsel and Duty of Care; and (b) the Tatung Defendants’ Cross-Motion to Bifurcate
Discovery, issued on May 8, 2007.
2. Attached as Exhibit A is a true and correct copy of LPL’s letter brief in
connection with its Motion to Compel Discovery Regarding Advice of Counsel, tiled on
December 22, 2006.
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3. Attached as Exhibit B is a true and correct copy of the Tatung Defendants’
Opposition to LPL’s Motion to Compel Discovery Regarding Advice of Counsel, filed on
January 8, 2007. _
4. Attached as Exhibit C is a true and correct copy of LPL’s letter brief to the
Special Master, filed on January 11, 2007.
5. Attached as Exhibit D is a true and correct copy of the Tattmg Defendants’
Supplemental Brief Regarding Advice of Counsel, filed on January 26, 2007.
6. Attached as Exhibit E is a true and correct copy of LPL’s Supplemental Brief
Regarding Advice of Counsel, filed on January 31, 2007.
7. Attached as Exhibit F is a true and correct copy of the Special Master’s Report
and Recommendation Regarding (a) LG. Philips’ Motion to Compel Tatung Defendants
to Provide Discovery on Advice of Counsel and Duty of Care; and (b) the Tatung
Defendants’ Cross-Motion to Bifurcate Discovery, issued on May 8, 2007.
8. Attached as Exhibit G is a true and correct copy of LPL’s Sixth Supplemental
Objections and Answers to Defendant Tatung Company’s First Set of Interrogatories,
dated April 6, 2007.
9. Attached as Exhibit H is a true and correct copy of LPL’s Seventh
Supplemental Objections and Answers to Defendant Tattmg Company’s First Set of
Interrogatories, dated May 4, 2007.
I declare under penalty of perjury under the laws of the United States of America
that the foregoing is true.
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Executed this 29th day of May 2007 in Santa Monica, Califomia.
Valerie W. H0
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UNITED STATES DISTRICT COURT
DISTRICT OF DELAWARE
CERTIFICATE OF SERVICE
I hereby certify that on May 29, 2007 I caused to be served by electronic mail and hand
delivery the foregoing document and electronically tiled the same with the Clerk of Court using
CM/ECP which will send notification of such iiling(s) to the following:
Richard D, Kirk, Esquire J effrey B, Bove, Esquire
The Bayard Firm James Heisman, Esquire `
222 Delaware Avenue #900 Jaclyn M, Mason, Esquire
Wiirnington, DE 19899 Connolly Bove Lodge & I-Iutz LLP
1007 North Orange Street
P.O, Box 2207
Wilmington, DE 19899
I hereby certify that on May 29, 2007 I caused to be sent the foregoing document by
electronic mail and Federal Express to the following nozvregistered participants:
Gaspare .1, Bono, Esquire Tracy R. Roman, Esquire
Rel S. Ambrozy, Esquire Raskin Peter Rubin & Simon LLP
Lora A, Brzezynski, Esquire 1801 Century Park East, Suite 23 00
Cass W, Christensen, Esquire Los Angeles, CA 90067
McKenna Long & Aldridge LLP
1900 K Street, N.W. Scott R, Miller, Esquire
Washington [IC, 20006 Connoily Bove Lodge & Hutz LLP
355 South Grand Avenue
Suite 3150
Los Angeles, CA 90071
Z it ( ,, C,b€>€f—;T
Frederick L. Cottrell, Ill (#2555)
[email protected]
R1.Fl—2967l3l—l

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