Free Letter - District Court of Delaware - Delaware

Case 1:05-cv-00298-JJF Document 83 Filed O4/25/2006 Paget of 2
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AIIORNEYS AT LAW
Cirizsiws BANK Camrra • siiirr 1300 • 919 Nonrn MARKET Srixrizr • RO. Box 2325 • WILMINGTON, DE 19899-2525
$02.6547444 • FAX 302.6;%.8920 • ww\v.foxroLhschild.com
Francis G.X. Pileggi
Direct Dial: (302) 622-4201
Internet Address: fpileggi@f`rof.com
April 25, 2006
VIA E-FILING
The Honorable Joseph J. Farnan, Jr.
United States District Judge
U.S. District Court for the
District of Delaware
844 King Street
Lock Box 27
Wilmington, DE 19801
Re: Seinfeld v. Barrett et al., C.A.. No 05-298 (JJF)
Dear Judge Farnan;
Although we have tried in good faith, regrettably the parties have not been able to submit
a Joint Stipulated Proposed Scheduling Order, although fortunately there is only one rather
simple difference in the proposed forms of Order and only one discrete issue for this Court to
decide in order to finalize the Scheduling Order. The only issue is on the number of depositions
that can be taken. Plaintiffs believe strongly that approximately eighty depositions are needed
based on the persons already identified in pleadings filed by Intel and the other Defendants in
this action thus far. Specifically, there are forty-six persons identified as being members of a
proxy team who worked on the proxy that is the focus of this litigation, in addition to the
directors and the executive officers identified in the proxy statement. Also, several experts have
already submitted what amounts to expert reports and of course of we need to depose them as
well. We also expect to depose an expert on executive compensation and an accountant as well
as persons identified on lntel’s website.
PENNSYLVANIA • Nizwrlnasisv • DELAWARL • NrwYoRx • FLORIDA
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Case 1:05-cv-00298-JJF Document 83 Filed O4/25/2006 Page 2 of 2
I would prefer to ask the Court for approval to take these depositions now, if they are
needed, as opposed to waiting until discovery is underway before requesting approval from the
Court to do so at this time.
Respectfully submitted,
/s/ Francis G.X. Pileggi, Esguire
Francis G.X. Pileggi (#2624)
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Enclosure
cc; Steven C. Norman, Esquire (via e-filing)
A. Amold Gershon, Esquire (via e-filing)
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