Free Letter - District Court of Delaware - Delaware

Case 1:05-cv-00292-JJF Document 200 Filed 05/30/2006 Page 1 of 1
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May 30, 2006
VIA ELECTRONIC MAIL
The Honorable Joseph lr Farnan, lr.
United States District Court
District of Delaware
844 King Street
Wilmington, DE l980l
Re: LG. Philips LCD C0. Ltd. v. Tatung Company et. al.,
CHA. No. 05-292 (JJF)
Dear Judge Farnan:
We write with respect to Plaintiffs Motion To Compel Deposition Testimony And For
Sanctions, and Plaintiffs Second Motion To Compel Deposition Testimony And For Sanctions
which were tiled on May 25 and 26 respectively (the "Motions"). Notably absent iiom the
Motions is a statement certifying that Plaintiff "made a reasonable effort to reach agreement" on
the matters set forth in the Motions as required by Delaware District Court Local Rule 7.l .l. In
fact, Plaintiff never contacted Defendants prior to tiling the Motions
Consistent with the Local Rules and long—star1ding Delaware practice, the parties should
make a good faith effort to resolve those disputes before the Court expands its resources
Defendants have requested Plaintiff to withdraw the Motions. Plaintiff has taken the position
that the colloquy between counsel during the depositions satisfies the Local Rule requirement to
rneet and confer. Defendants disagree. The parties should engage in a meaningful meet and
confer, and if the parties are unable to reach agreement on the issues in dispute, Plaintiff can re-
tile the Motions and Defendants will respond pursuant to the Scheduling Order entered in this
action.
If the Court should have any questions or concerns, undersigned counsel remains
available at the Conrt’s convenience,
Res I
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RWWI lll Robert W. Whetzelf
cc: Richard D. Kirk, Esquire (By Electronic Filing and Hand Delivery)
Gaspare J . Bono, Esquire (By `felecopy)
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