Free Declaration - District Court of Delaware - Delaware

Case 1:05-cv-00023-JJF

Document 141

Filed 04/10/2008

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE DOW CHEMICAL CANADA, INC. on its own behalf and as assignee of THE DOW CHEMICAL COMPANY, ) ) ) ) Plaintiff, ) ) v. ) ) HRD CORPORATION ) (d/b/a Marcus Oil & Chemical), ) ) Defendant, Counterclaim Plaintiff, )

C.A. No. 05-23 (JJF)

LOCAL RULE 7.1.1 CERTIFICATION Counsel for Defendant/Counterclaim Plaintiff HRD Corporation d/b/a Marcus Oil & Chemical hereby certifies that reasonable efforts (as set forth in the motion) were made to reach agreement with Plaintiffs/Counterclaim Defendants Dow Chemical Canada, Inc. and The Dow Chemical Company regarding the matters set forth in the Emergency Motion To Take Photographs At Its Plant Inspection, Motion To Compel Production Of Documents, Motion To Re-Inspect Plant And For Sanctions that was filed on April 10, 2008, and that the parties were unable to reach a complete agreement with respect to those matters. OF COUNSEL: William C. Ferebee Michael Landrum O'DONNELL FEREBEE MEDLEY & KEISER, PC 450 Gears, Eighth Floor Houston, TX 77067-4512 (281) 875-8200 (telephone) (281) 875-4962 (facsimile) Dated: April 10, 2008
859624/28882

POTTER ANDERSON & CORROON LLP By: /s/ W. Harding Drane, Jr. W. Harding Drane, Jr. (#1023) Richard L. Horwitz (#2246) Suzanne M. Hill (#4414) Hercules Plaza, 6th Floor 1313 N. Market Street Wilmington, DE 19899-0951 (302) 984-6000 [email protected] [email protected] [email protected] Attorneys for HRD Corporation

Case 1:05-cv-00023-JJF

Document 141

Filed 04/10/2008

Page 2 of 2