Free Letter - District Court of Delaware - Delaware


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Date: April 9, 2007
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State: Delaware
Category: District Court of Delaware
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‘““'“¥’“'“‘“€}a‘§E*"l*%Yl'¤?l-“=iE':\‘f·‘t}O343-JJF `Document 621 -2 Fi|ed`O4/09/2007 ` Page "lPi§§3{’6f3
_ Tracy Roman _
From: Tracy Roman ;
Sent: Tuesday, March 13, 2007 4:31 Pl\/l V
To: Ambrozy, Rel; [email protected]; Auito, Derek
Subject: RE: Deposition Postponement A
Rel: ._
1. Yes, we agreed to postpone the 30(b)(6) technical witness Tommy Jue for the reasons raised by Scott during
yesterday's call, and we also agreed to move the deposition of Sally Wang to accommodate your schedule. Both
of these are postponed until at least April 20th. To follow up, Tommy Jue appears to have availability April 20, 24,
25, 26, and 27. He is not available April 23. Sally Wang appears to have availability on April 20, 24, and 25. She
is not available April 23, 26, or 27. As to the other witnesses, I am aware that Derek requested they get pushed
off, but I am not aware of an agreement yet, so l'll ask Scott to respond that issue. 2
2. ViewSonic agreed to sell the monitors identined in LPl.'s previous correspondence except as to any monitors
for which we only have a single sample available, in which case, we will make the product available for inspection
in D.C., unless it has previously been inspected in California. · 4. _
3. l have confirmed that ViewSonic is having monitors shipped with the expectation that they will be delivered in
time for your inspection to start on l\/larch 19, as you requested, barring any unforeseen catastrophe such as
weather, hijacking, act of God, etc., that prevents the truck from getting through.
4. Yes, ViewSonic agrees LPL can have until April 13 to supplement its interrogatory response identifying
accused products. 5 ·
Regards, i
Tracy _
Tracy R. Roman 1 ·
Baskin Peter Rubin & Simon, LLP
1801 Century Park East, Suite 2300 V
Los Angeles, CA 90067
Tel: 310.277.0010 »·
Fax: 310.277.1980 ; V
From: Ambrozy, Rel [mailto:[email protected]]
Sent: Tue 3/13/2007 3:43 PM r
To: Tracy Roman; [email protected]; Auito, Derek
Subject: RE: Deposition Postponement: _
Tracy: :4 j
Here are the details as I remember them: i 1
1. We agreed to postpone the depositions of ViewSonic's 30(b)(6) witness as well as the deposition of Sally
Wang, Eric Willey, David Lee, Gene Hsiao, Alex Huang, Victoria Yip, Tony Huang, James Sung and ll/lr. Zapka
(please note the rescheduling of the 8 last witnesses was raised by Derek Auito after our call) until at least April
20th. .
2. ViewSonic agreed to sell the monitors identihed by LPL in LPL's previous correspondence (we received your
letter sent last night providing price information, and will identity on Wednesday which products we wish to
purchase). _
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‘"“*"’°*‘C’as‘e’n*t0’4*FcV¤00343—JJF Document 621 -2 Filed 04/09/2007 Page 2 p>jg§ 2 cfg
3. ViewSonic agreed to make available for inspection certain other monitors.
TRACY - Pursuant to our previous requests asking for an inspection on li/iarch 12 and 13 in Washington, D.C., on
which we never received a response, PLEASE NOTE that we would like to conduct that inspection March 19 and
20 (or until the inspection is complete). Given we have already lost this week for inspection, please advise shortly
whether these dates work so that we can make the proper arrangements.
4. LPL will supplement its interrogatory response identifying accused products by April 13.
We look forward to your response. . k
nw, Rei.
From: Tracy Roman [mailto:TRoman@rasl Sent: Tuesday, March 13, 2007 5:02 PM
To: Ambrozy, Rel
Subject: RE: Deposition Postponernent
Can we wait until Thursday simply because Scott's not going to be on this cali and l think he has the necessary
details? ,
Tracy R. Roman t
Ras kin Peter Rubin & Simon, LLP ,
1801 Century Park East, Suite 2300
Los Angeles, CA 90067 . 1
Tel: 310.277.001O i
Fax: 310.277.].980 _ :
From: Ambrozy, Rel [mailto:[email protected]]
Sent: Tue 3/13/2007 2:00 PM
To: Tracy Roman {
Subject: Deposition Postponement l
Tracy: I would like to put something on the record about our call
yesterday, but have not seen the "terms" that we discussed. Do you want
to hash those out now via email during the call and put the terms on the
record at the end ofthe call, or wait until T‘hursday's call ‘? ·
'llmx, Rel.
Rel S. Ambrozy
McKenna Long & Aldridge
1900 K Street, N.W.
Washington, DC 20006
202.4%.7500 (w) 202.496.7756 (t) y
[email protected]
www.mckerma1ong.com
Atlanta * Denver * Los Angeles * Philadelphia * San Diego * San
Francisco * Washington, D.C. * Brussels
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This electronic message transmission contains infomation from the law
frm of McKenna Long & Aldridge, which may be confidential or protected
l
4/6/2007

‘·"r“"*‘G*as‘e’°I“t0’4*>cv*~G0343¢JJF"° Document 621 -2 Filed O4/O9/2007 Page 3 Beigt 3 of 3 _
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" 4/6/2007 I

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