Case 1:05-cv-00292-JJF Document 201 Filed 05/31/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
LG.PHILH’S LCD CO., LTD.,
V. Civil Action No. 05-292 (JJF)
TATUNG COMPANY; I
TATUNG COMPANY OF AMERICA, INC.;
CHUNGHWA PICTURE TUBES, LTD.;
AND VIEWSONIC CORPORATION,
LOCAL RULE 7.1.1 STATEMENT IN SUPPORT OF
PLAINTIFF’S MOTION TO COMPEL DEPOSITION TESTIMONY
AND FOR SANCTIONS |D.I. 198]
The undersigned attorney for plaintiff, LG.Philips LCD Co., Ltd. ("LPL") hereby states,
pursuant to Local Rule 7.1.1, that LPL’s attorneys have made a reasonable effort to reach
agreement with opposing counsel on the matters set forth in LPL’s Motion to Compel Deposition
Testimony and for Sanctions (the "Motion") [D.I. 198]. Specifically, counsel states the
(1) The Motion deals with depositions LPL is taking of defendants on an expedited
basis in preparation for the trial that will commence on July 17. The Motion seeks relief as a
result of defense counsel’s repeated improper instructions to the deponents not to answer and
repeated improper coaching of deponents through objections and inteij ected questions.
(2) LPL’s counsel repeatedly asked defense counsel to refrain from making improper
objections and from coaching the witnesses, as shown throughout the transcripts that were
attached to the Motion as Exhibits 1-4. Despite repeated requests to refrain, defense counsel did
Case 1:05-cv-00292-JJF Document 201 Filed 05/31/2006 Page 2 of 3
(3) LPL’s counsel informed defense counsel repeatedly that continued improper
deposition behavior would require LPL to seek relief from the Court. LPL’s counsel sent
defense counsel written notice before the Motion was tiled that LPL would be seeking relief
from the Court.
May 31, 2006
THE BAYARD FIRM
Richard"]; Kirk (rk0922)
222 Delaware Avenue, Suite 900
P.O. Box 25l30
Wilmington, DE 19899-5 130
Counsel for plaintiff,
LG.Philips LCD Co., Ltd.
Case 1:05-cv-00292-JJF Document 201 Filed 05/31/2006 Page 3 of 3
CERTIFICATE OF SERVICE
The undersigned counsel certifies that, on May 31, 2006, he electronically tiled
the foregoing document with the Clerk of the Court using CM/ECF, which will send
automatic notification of the tiling to the following:
Robert W. Whetzel, Esq.
Matthew W. King, Esq.
Richards, Layton & Finger
One Rodney Square
P.O. Box 551
Wilmington, DE 19899
The undersigned counsel further certifies that copies of the foregoing document
were sent on May 3 l, 2006 by email and by hand to the above counsel and by email and
tirst class mail to the following non-registered participants:
Christine A. Dudzik, Esq. Teresa M. Corbin, Esq.
Thomas W. Jenkins, Esq. Glenn W. Rhodes, Esq.
Howrey LLP Julie Gabler, Esq.
321 North Clark Street Howrey LLP
Suite 3400 525 Market Street
Chicago, IL 60610 Suite 3600
San Francisco, CA 94105
/s/ Richard D. Kirk (rk0922l
Richard D. Kirk