Free Letter - District Court of Delaware - Delaware

Case 1 :05-cv-00160-KAJ-l\/I PT Document 95-2 Filed O2/28/2006 Page 1 of 4
Novoqymes A/S v. Genencar Int ’l, Inc. and EDC
TIMELINE
February 9, 2006 Pretrial Hearing - Judge Jordan told NZ that it must make witnesses
9:30 am available to GCOR and produce additional documents.
February 9, 2006 G. Lanier email to D. Tellekson — Demanding that NZ produce
2:14 pm additional documents by 02/15, and stating that GCOR intended to
depose at least Borchert, Garbell, Holbo, Svendsen and Bisgaard-
Frantzen, reserving right to take additional depositions concerning
the "Waived Subjects" after review ofthe requested documents.
February ll, 2006 R. Sullivan email to G. Lanier — Asking for GCOR’s additional
depositions requests as soon as possible, and claiming to have
produced all documents on "Waived Subjects." Also, produces
informal Arnold report, which NZ claims will provide the basis for
her supplemental report, which it will produce on 02/ 13/06.
February 12, 2006 G. Lanier email to R. Sullivan — Continuing to demand additional
documents, and asking for Borchert, Holbo, Bisgaard-Franzen,
Svendsen and Egede deposition dates. Also asks for explanation
why new experimental data (including 12/19 Jorgensen declaration)
was not produced earlier.
February 13, 2006 K. Reiner email to G. Lanier - Making C. Jorgensen available for
deposition on 02/16 or 02/17. Also asks to know which depositions
GCOR really intends to take.
February 13, 2006 K. Reiner email to G. Lanier — Inforrning GCOR that the "ramp—up"
time experiments were conducted by J eppe Wegener Tams and
Mette Bjorn Egede, and asking whether GCOR intends to depose
them as well.
February 13, 2006 G. Lanier email to K. Reiner - Stating that GCOR does want to
depose C. Jorgensen, J. Tams and all others previously mentioned
(Borchert, Garbell, Holobo, Svendsen and Bisgaard-Frantzen).
February 13, 2006 K. Reiner email to G. Lanier - Providing some translations.
February 13, 2006 G. Lanier email to K. Reiner - Confirming C. Jorgensen deposition
on 02/17/06.
February 13, 2006 K. Reiner email to G. Lanier — Stating that due to weather, Arnold
supplemental report may not be available until 02/ 14/06.
February 13, 2006 G. Lanier email to K. Reiner — Asking again for deposition dates
ASAP for "Borchert, Holbo, Tams, Paulsen, and Amo1d."
February 14, 2006 Telephone conference between counsel re: documents and
deposition scheduling.

Case 1 :05-cv-OO1 60-KAJ-IVI PT Document 95-2 Filed 02/28/2006 Page 2 of 4
February 14, 2006 R. Sullivan email to G. Lanier — Offering deposition dates for Tams
and Arnold, and indicating that Borchert, Holbo, and Egede are still
"to be determined."
February 14, 2006 G. Lanier email to R. Sullivan — Confirming Jorgensen, Tams and
Arnold deposition dates and times, and requesting Borchert, Holbo
and Egede ASAP. Also withdrew request to take Paulsen
deposition.
February 15, 2006 NZ produced Arnold Second Rebuttal Report and additional
Jorgensen documents.
February 15, 2006 R. Sullivan email to G. Lanier — Providing deposition date for
Borchert.
February 16, 2006 G. Lanier email to R. Sullivan - Confirming Borchert deposition
date, and asking again for Holbo and Egede deposition dates.
February 17, 2006 R. Sullivan email to G. Lanier - Of`f`ering Holbo deposition for
03/02/06 (same day as Borchert), and stating that NZ will not offer
Egede as a witness at trial.
February 17, 2006 G. Lanier email to R. Sullivan - Confirming that GCOR still wants
to take Egede deposition, and stating that 03/02/06 is not an
acceptable date for the Holbo deposition.
February 20, 2006 G. Lanier email to K. Reiner - Demanding additional documents
currently on NZ privilege log.
February 21, 2006 K. Reiner email to G. Lanier - Stating that Holbo is only available
on 03/03 and that Egede is also available on that day. Also
produced additional documents.
February 21, 2006 G. Lanier email to K. Reiner - Stating that GCOR does not agree to
take the Holbo and Egede depositions on the same day, 03/03/06.
Also asked that NZ make Holbo and Egede available during
February 27 - March 1, each on a different day.
February 21, 2006 K. Reiner email to G. Lanier - Confirming that Holbo is available
for deposition on 03/03/06, and stating that they are checking
Egede’s availability.
February 21, 2006 G. Lanier email to K. Reiner - Stating that GCOR would ask the
Court for discovery relief
February 21, 2006 K. Reiner email to G. Lanier - Stating that they reviewed the entries
on NZ’s privilege log that GCOR contends relate to the "Waived
Subjects," and complaining about the length of GCOR’s list. Also
stated that they found no documents subject to the waiver that have
not already been produced. Did not provide any further information
about those privilege log entries.
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Case 1 :05-cv-OO1 60-KAJ-IVI PT Document 95-2 Filed 02/28/2006 Page 3 of 4
February 21, 2006 G. Lanier email to K. Reiner - Explaining the manner in which
GCOR chose entries on NZ’s privilege log that required fiuther
information and! or production, and noting that it is NZ’s burden to
justify the identified entries on its privilege log, because it is NZ
that is attempting to withhold documents.
February 22, 2006 G. Lanier email to K. Reiner — Stating that the Court had set a
schedule regarding GCOR’s complaint about deposition
scheduling, and proposing a possible compromise to the issue.
February 22, 2006 G. Lanier email to K. Reiner - Following-up to a telephone
conversation between the two regarding the compromise that had
been reached concerning deposition scheduling.
February 22, 2006 K. Reiner email to G. Lanier - Confirming compromise regarding
deposition scheduling.
February 22, 2006 G. Lanier email to K. Reiner - Stating that, based on the parties’
compromise, GCOR would not seek relief fiom the Court regarding
deposition scheduling.
February 22, 2006 K. Reiner email to G. Lanier — Stating that NZ was under no
obligation to explain the privilege log entries about which GCOR
requested further information.
February 24, 2006 G. Lanier email to K. Reiner - Seeking confirmation on NZ’s
position regarding the privilege log issue, and inviting NZ to
reconsider the issue as to at least those documents marked by NZ at
the Garbell deposition. Also stated that GCOR would ask the Court
for relief if the parties could not work out this issue.
February 24, 2006 G. Lanier email to K. Reiner - Asking for more information
regarding documents concerning previously undisclosed
experiments, which NZ produced that day. Also demanded that NZ
produce all documents, in their unredacted form, that relate to those
experiments, including the results of the experiments.
February 24, 2006 K. Reiner email to G. Lanier - Stating NZ’s position that it was
under no obligation to explain why a document on its privilege log
is not subject to the limited waiver or prove to GCOR that NZ has
made a full production.
February 26, 2006 G. Lanier email to K. Reiner — Seeking clarification regarding
recently produced documents.
February 26, 2006 K. Reiner email to G. Lanier - Providing clarification regarding
recently produced documents.
February 26, 2006 G. Lanier email to K. Reiner - Seeking further clarification
regarding recently produced documents.
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Case 1 :05-cv-OO1 60-KAJ-IVI PT Document 95-2 Filed O2/28/2006 Page 4 of 4
February 26, 2006 K. Reiner email to G. Lanier - Providing further clariiication
regarding recently produced documents.
February 27 , 2006 K. Reiner email to G. Lanier - Stating that while NZ has no
obligation to do so, it would provide GCOR with some more
information about redacted documents.
February 27, 2006 K. Reiner email to G. Lanier - Providing more information about
redacted documents.
Febmary 27, 2006 G. Lanier email to K. Reiner - Reasserting GCOR position that NZ
must provide ihrther information regarding all ofthe privilege log
entries about which GCOR sought information.
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