Free Redacted Document - District Court of Delaware - Delaware

Case 1 :06-cv-00077-JJF Document 85 Filed 01/16/2008 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
BALDWIN GRAPHIC SYSTEMS, INC.,
M ptagmifg REDACTED VERSION
v` Civil Action No. 06-077-JJF
F IBERWEB SIIVIPSONVILLE, INC. and
FIB ERWEB, INC.,
Defendants.
DECLARATIONMOF KEVIN DHJL IN OPPOSITION TO
PLAINTIFF’S MOTION FOR IN CAMERA REVIEW AND TO COIVIPEL
_ PRODUCTION OF DOCUMENTS
I, Kevin Dill, do hereby state, upon personal knowledge, under the pains and penalties of
perjtuy, the following:
MMWWW l. During the 2003 to 2005 timeframe, I was a Fibeiweb employee with managerial
responsiliilmniesinJMMMJMJWJJIMMMMHMMMMWMMMJMJMJMMMMJMJMMMMMHMMMMUMMWMMUMMMMJJWMMMMHNUHUMJMJMWMWJMNMMMMMMMlUMMJMMMHJJIJIMMJMMM—JMMMMMnm-lJJm——M_l_—wlmmm”
2, I have reviewed document 82 bearing production nu1nberFW0l767O in
unredacted form.
3. Document 82 is an e-mail by me to Joann Salek dated November I0, 2003.
4. At the time I wrote this email, Joann Salek was Business Director at Fibexweb.
5. Scott Anderson, James Briggs, Steve Goodpaster, and Julian Gudgeon were
copied on the e~mail.
6. To the best of my knowledge, at the time I wrote this email, Scott Anderson was a
sales manager at Fiberweb.
BOS~l iszsso vl

Case 1 :06-cv-00077-JJF Document 85 Filed 01/16/2008 Page 2 of 4
7. To the best of my knowledge, at the time I wrote this email, James Briggs was a
market manager at Fiberweb.
8. To the best of my knowledge, at the time I wrote this email, Steve Goodpaster
was a market manager at Fibeiweb.
9. To the best of my knowledge, at the time I wrote this email, Julian Gudgeon was a
market manager at Fiberweb.
10. Prior the writing this e-mail, Iunderstood that
REDACTED
ll. In document 82, I relay to Joann Salek the status of t
REDACTED
12. The people copied on the e-mail document 82 were copied because
REDACTED
13. From my perspective all information about the research and development ofthe
Washtex II Premoistened project was and still is highly confidential to Fiberweb and to the best
of my knowledge only Fibeiweb employees have had access to such information.
14. I have reviewed document 113 bearing production number FWOO64l3 in
unredacted form.
15. Document 113 is an e—mail from me to Gerd Lindemann and Roy Howard dated
December 22, 2005.
16. At the time Iwrote this email, Gerd Lindemann was Graphic Arts Salesman at
Fibeiweb Europe.
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Case 1 :06-cv-00077-JJF Document 85 Filed 01/16/2008 Page 3 of 4
17. At the time I wrote this email, Roy Howard was Graphic Arts Sales Manager at
BBA Fiberweb Europe.
18, The Graphic Arts division at Fiberweb encompasses the ELIXIR® product.
19. Steve Major, Philippe Quertain, James Briggs, and J on Howey were copied on
this e—mai1.
20. At the time I wrote this email, Steve Major, Gerd Lindemann, and Philippe
Quertain were all Graphic Arts Salesman reporting to Roy Howard at BBA F iberweb Europe.
21. To the best of my knowledge, at the time I wrote this email, James Briggs was the
sales director in charge the ELIXIR® product.
22. At the time I wrote this email, Ion Howey was a developmental fellow at
Fiberweb who participated in the development of the ELIX[R® product.
23. Jo H' e and I
” °"’ Y REDACTED
24. In the redacted portion of this e—mail, I
REDACTED
25. To the best of my knowledge, the substance of the statement in the redacted
portion ofthe e-mail was not distributed outside ofFibe1web.
Dated: January $1, 2008 --e»....__. · ·
Kevi Dill
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Case 1:06-cv-00077-JJF Document 85 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 Bled a true and correct copy of the foregoing document with the Clerk of
the Court using CM/ECF, which will send notification that such filing 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 of the foregoing document
to be served by hand delivery and e—mai1 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 10281-2101
/s/ Francis DiGio_vanni ___
Francis DiGiovanni (#3189)