Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv—00343-JJF Document 593-2 Filed O3/19/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
LG Philips L-CD Col, ) CA. Noi: 04—343—·.l.IF
Plaintiff, ) JURY TRIAL DEMANDED
is i
Tatung Co, Tatung Company of America Inc, )
and Viewsonic Corp. )
}
Defendaxtts )
Declaration of Valerie W. H0
I, Vaierie W. Ho, declare:
I. I am a shareholder offlrcenberg Traurig, LLP, one ofthe law firms
representing `iatttng Company and Tatung Company of America, ldetended the
deposition Kevin I-lo, a Tatung Company employee, on March I4, 2007.
2, During the course of Mr. l—lo’s deposition, he was asked whether he discussed a
particuiai subject (discounts to HP for product promotion) with me during a break. In
fact, there had been no substantive discussions between Mr, Ho and me during the break,
Although the subject that Mr. Christensen inquired about had not been discussed, l was
concerned that if Mr., Ho answered the specific question as phrased, LG Philips would
claim that the attorney client privilege had been waived Consequently, l instructed him
not to answer the question
3. The questions and answers leading up to my instruction appear starting on page
128, line I ofthe Ho transcript and end on page lJ30, line i4. A true copy ofan except of
the rough transcript containing those pages is attached as Exhibit A.
ta rzswsozszin azisrzour
1 i

Case 1:04-cv—OO343-JJF Document 593-2 Filed O3/19/2007 Page 2 of 2
4. Because Mr. Ho was not asked whether there had been consultatiori with
counsel during the break, but rather whether 2. particular subject had been discussed with
counsel, I believe my objection and instruction were proper.
I declare urrder penalty of perjury under the laws of the United States of America
that the foregoing is true.
. . idea . .
Executed this `_ """” day of March 2007 in Santa Momca,
California.
f J)

Valerie W. Ho
ra rzawsazazvr axrazzaor
2 I

Case 1:04-cv-00343-JJF

Document 593-2

Filed 03/19/2007

Page 1 of 2

Case 1:04-cv-00343-JJF

Document 593-2

Filed 03/19/2007

Page 2 of 2