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FILED ELECTRONICALLY
ORIGINAL BY HAND
. April 24, 2006
The Honorable Joseph J. Farnan, Jr.
United States District Court
844 North King Street
Wilmington, DE 19801
RE: LG.PlziZ1ps LCD C0., Ltd. v. Tattmg Conzpazzy 0fAnzercia, et al.
C.A. No. 05-292-JJE
Dear Judge Farnan:
I In addition to the issues raised in Mr. King's letter of today's date, Plaintiff would
like to address at tomorrow's hearing the remaining fact and expert discovery deadlines
for this case.
Enclosed is a proposed order setting forth Plaintiffs proposed deadlines. We have
discussed this proposed schedule with Defendants counsel, but have been unable to reach
an agreement. Therefore, we seek the Court's assistance.
Respectfully submitted,
» l /s/ Richard D. Kirk (rk0922) A
RDK/slh
cc: Clerk of the Court (by hand)
All counsel as shown on the attached certificate
616777vl
Case 1:05-cv-00292-JJF Document 176 Filed O4/24/2006 Page 2 of 4
i IN THE UNITED STATES DISTRICT COURT h
FOR THE DISTRICT OF DELAWARE
LGPHILIPS LCD CO., LTD., {
. Z `
PlaintifHCounterclairn Defendant, I
I
V. E
i Civil Action No. 05-292 (JJF)
I
· · I
TATUNG COMPANY; TATUNG COMPANY {
OF AMERICA, INC.; CHUNGHWA PICTURE {
TUBES, LTD.; AND VIEWSONIC ;
CORPORATION, :
Defendants. Q
I
I
I
PROPOSED ORDER SETTING DISCOVERY DEADLINES
The Court having issued a Joint Rule 16 Scheduling Order on December 21, 2005, and
the Court having concluded that certain deadlines in the Joint Rule 16 Scheduling Order need to
be reset, IT IS ORDERED that:
1. Depositions may commence on or after May 1, 2006. Fact depositions and Rule
30(b)(6) depositions must be completed by May 19, 2006. . I
I 2. Reports from retained experts required by Fed. R. Civ. P. 26(a)(2) relating to each
parties burden of proof are due by May 26, 2006; all rebuttal expert reports are due by June 2,
2006.
3. Any party desiring to depose an expert witness shall notice and complete said S `
deposition no later than June 13, 2006, unless otherwise agreed in writing by the parties or
ordered by the Court.
Case 1:05-cv-00292-JJF Document 176 Filed O4/24/2006 Page 3 of 4
4. The Joint Rule 16 Scheduling Order continues to govern in all other respects. â€
DATE V UNITED STATES DISTRICT IUDGE
Case 1:05-cv-00292-JJF Document 176 Filed O4/24/2006 Page 4 of 4
CERTIFICATE or SERVICE "
The undersigned counsel certifies that, on April 24, 2006, he electronically filed
the foregoing document with the Clerk of the Court using CM/ECF, which will send
automatic notification of the filing to the following: `
Robert W. Whetzel, Esq.
Matthew W. King, Esq.
Richards, Layton & Finger
One Rodney Sqare
P.O. Box 55l I
Wilmington, DE 19899
The undersigned counsel further certifies that copies of the foregoing document
were sent on April 24, 2006 by email and by hand to the above counsel and by email and
first 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 Howrey LLP
32l North Clark Street 525 Market Street
Suite 3400 Suite 3600
Chicago, IL 60610 San Francisco, CA 94105
/s/ Richard D. Kirk (rk0922[
g Richard D. Kirk _
602380vl