Free Redacted Document - District Court of Delaware - Delaware

Case 1 :06-cv-00077-JJF Document 86-2 Filed 01/16/2008 Page 1 of 4
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IN THE UNITED STATES DISTRICT COURT
FOR TI-IE DISTRICT OF DELAWARE
BALDWTN GRAPHIC SYSTEMS, INC.,
A p p pp p p p p p p p p REDACTED VERSION
___ V` Civil Action No. 06-077-JJF {
FIBERWEB SJMPSONVILLE, INC. and
FIBERWEB, INC.,
Defendants.
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TO PLAlZNTIFF’S MOTION FOR IN CAMERA REVIEW AND TO COIVIQPEL
PRODUCTION DF DOCUMENTS ~
I, James Briggs, do hereby state, upon personal lcnowledge, under the pains and penalties
of perjury, the following:
_,,,,,,,,, , ,,,,, ,,__ ,,,,,, M,,M,MNN,MNMN_NNMMNWNNMNMNNN_NMMWW_NMNNM1;NNNNWMNW_§rave_reyi“ewed“dpcmnent 109 bearing production. number FW028792 in
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2. Document 109 is an email written by me on January 9, 2007 addressed to Ed
Thomas.
3. At the time I wrote this email, Iwas the sales director in charge the ELIXIR®
product at Fiberweb.
4. At the time I wrote this email, Ed Thomas was vice president of research and
development at Fiberweb.
5. Derek Anderson, Darrell Dean, Jim O’Connor, Jerry McCarty, Kevin Dill, Jon
Howey, Mark Berman, and Tom Taylor were copied on this email.
6. At the time I wrote this email, Derek Anderson was President at Fiberweb,
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Case 1 :06-cv-00077-JJF Document 86-2 Filed 01/16/2008 Page 2 of 4
7, At the time I wrote this email, Darrell Dean was Maintenance & Engineering
Manager at Fiberweb.
8. At the time I wrote this email, Jim O’Connor was Facility Manager at Fiberweb.
9. At the time I wrote this email, Jerry McCarty was Project Engineer at Fiberweb.
10. At the time I wrote this email, Kevin Dill was Product Director for the ELIXlR.® I
product at Fiherweb.
11. At the time I wrote this email, Jon Howey was a developmental fellow at
Fiberweb who participated in the development ofthe ELIXIR® product.
12. At the time I wrote this email, Mark Berman was Hygiene Business Manager at
Fiherweb.
13. At the time 1 wrote this email, Tom Taylor was a Process Engineering Leader at
the Gray Court facility which manufactures the fabric used in the ELIXIR® product.
14. At sometime before I wrote this email, Jon Howey and I had discussions with
Michael Zeliger and Jackson Ho, outside counsel to Fiberweb, about REDACTED
15. Michael Zeliger and Jackson Ho advised Jon Howey and I concerning
REDACTED
16. In the email of Document 109, Irelayed outside counsels’ advice to Fiberweb
employees in a position to provide input concerning counsels° advice.
17. I have reviewed document 141 bearing production number FW006337 in
unredacted form.
18. Document 141 is an email from Tom Taylor to me and Ed Thomas dated J anuaiy
11, 2007.
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Case 1 :06-cv-00077-JJ F Document 86-2 Filed 01/16/2008 Page 3 of 4 I
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19. This email was a response to my email document 109 identified above in
paragraph 2 of this declaration.
20. The same people that were copied in email document 109 were copied on this
email as well.
2l. In this email, Tom Taylor responded to my email document 109 and presented
some options regarding outside c0unsels’ advice.
22. From my perspective all information about an internal trial or project at our
manufacturing plant would have been considered confidential to everyone involved in this
project and to the best of my knowledge only Fiberweb employees have had access to such
information.
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Dated: January 9, 2008 _____T_\ gfgbi Qi
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a . Case 1:06-cv-00077-JJF Document 86-2 Filed O1/16/2008 Page 4 of 4
CERTIFICATE OF SERVICE
I, Francis DiGiovanni, hereby certify that on January 9, 2008, I caused to be
electronically tiled a true and correct copy of the foregoing document with the Clerk of
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the Court using CM/ECF, which will send notification that such tiling is available for
viewing and downloading to the following counsel of record:
Jack Blumenfeld, Esquire
Morris, Nichols, Arsht & Tunnell
1201 N. Market Street
P.O. Box. 1347
Wilmington, DE 19899
I further certify that on this same date I caused a copy ofthe foregoing document
to be served by hand delivery and e-mail on the above-listed counsel of record, and by
Federal Express and e-mail on the following counsel of record:
Keith J . McWha, Esquire
James W. Gould, Esquire
Morgan & Finnegan
3 World Financial Center
New York, NY 1028l—2l01
/s/ Francis DiGiovanni _
Francis DiGiovanni (#3189)