Free Letter - District Court of Delaware - Delaware


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Date: December 31, 1969
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Category: District Court of Delaware
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Case 1 :05-cv-00485-JJF Document 512 Filed 1 1/08/2007 Page 1 of 2
PRICKETT, JONES & ELLIOTT
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November 8, 2007
BY HAND AND VIA E-FILING
The Hon. Joseph J. Farnan, Jr.
United States District Court
for the District of Delaware
844 King Street
Wilmington, DE 19801
A RE: DM 7; In Re: Intel Corp. Microprocessor Antitrust Litigation, MDL N0. 05-1717-
JJF; Paul v. Intel Corg., Cons. C.A. N0. 05-485-JJF
Dear Judge Farnan:
Class Plaintiffs are tiling today their Reply Memorandum in Support of Plaintiffs’ Rule
53(g) Objections to Special Master’s Report and Recommendation Compelling Production of
_ Class Plaintiffs’ Financial Doctunents in Discovery Matter No. 7. We realize that Your Honor
entered an Order on October 22, 2007 adopting the Special Master's Report and
Recommendation based on the assumption that Class Plaintiffs had not tiled objections to the
Report and Recommendation. We moved for reconsideration because, in fact, objections were
timely tiled (D.I. 614 in 05—md—l717).1 Your Honor has not yet ruled on our motion. Intel has
tiled an answering brief opposing Class Plaintiffs’ objections in accordance with the time frame
set by the rules and measured from the date of our objections. We do not want to presume on the
Court's judgment on our motion for reconsideration, but we do believe that it is appropriate to
keep the briefing on our objections on schedule pending Your Honor's ruling.
Also, Class Plaintiffs’ reply submission makes reference to certain fee agreements
between the proposed class representatives and their counsel. Although these fee agreements
may inform Your Honor’s analysis of the privilege issues that are the subject of this dispute,
these fee agreements are highly sensitive and we are extremely reluctant to disclose them to Intel
or AMD, even subject to a "confidential" designation pursuant to Your Honor’s September 26,
2006 Protective Order. We therefore respectfully request that, if Your Honor wishes to review a
representative sample of these fee agreements, Class Plaintiffs be permitted to submit the
1 As set forth in Class Plaintiffs’ motion for reconsideration, which Intel does not oppose, it appears that the Court
may not have detected Class Plaintiffs’ objections due to an apparent docket entry numbering error in the Court’s
electronic case tiling system.
196s4.1us123svr

Case 1:05—cv—00485-JJF Document 512 Filed 11/08/2007 Page 2 of 2
The Hon. Joseph J. Farnan, Jr.
November 8, 2007
Page 2
agreements for an in camera inspection. We are prepared to provide the sample fee agreements
to Your Honor immediately upon request.
Counsel are available at the call of the Court to address any questions that Your Honor
may have.
Respectfully submitted,
¤. 4%;
é es L. Holzma
I! Bar ID No. 663)
JLH/sam
cc: Richard L. Horwitz, Esq.
Frederick L. Cottrell, III, Esq.
Dr. Peter T. Dalleo, Clerk of the Court
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