Free Affidavit - District Court of Delaware - Delaware

Case 1 :04-cv-01436-JJF Document 89 Filed 01 /26/2006 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ST. CLAIR INTELLECTUAL PROPERTY )
CONSULTANTS, INC. )
)
Plaintiff, )
)
v. ) Civil Action No. 04-1436 JJF
)
SAMSUNG ELECTRONICS CO., LTD., SAMSUNG )
ELECTRONICS AMERICA, INC., SAMSUNG ) JURY TRIAL DEMANDED
TELECOMMUNICATIONS AMERICA, L.P., )
MATSUSHIT A ELECTRIC INDUSTRIAL CO., _ )
LTD., MATSUSHITA ELECTRIC CORPORATION )
OF AMERICA, VICTOR COMPANY OF JAPAN, )
LTD., JVC COMPANY OF AMERICA, NOKIA )
CORPORATION, NOKIA, INC., HEWLETT- )
PACKARD COMPANY, EASTMAN KODAK )
COMPANY, )
)
Defendants. )
)
AFFIDAVIT OF PATRICIA P. MCGONIGLE IN SUPPORT OF PLAINTIFF ST.
CLAIR’S MOTION FOR AN ORDER COMPELLING DEFENDANT EASTMAN
KODAK COMPANY TO SUBSTANTIVELY RESPOND TO PLAINTIFF’S
OUTSTANDING DISCOVERY REQUESTS AND TO MOVE FORWARD WITH
OWNERSHIP-RELATED DISCOVERY IN THIS CASE
I, Patricia P. McGonig1e, declare as follows:
I. I am an attorney with the law firm of Seitz, Van Ogtrop & Green, counsel
representing Plaintiff in the above-captioned action.
2. I am admitted to practice before this Court.
3. g This Affidavit is submitted in support of Plaintiff St. Clair’s Motion for an Order
Compelling Defendant Eastman Kodak Company to Substantively Respond to Plaintiffs
Outstanding Discovery Requests and to Move Forward with Ownership-Related Discovery in
this Case, dated January 26, 2006.

Case 1 :04-cv-01436-JJF Document 89 Filed 01 /26/2006 Page 2 of 4
4. Attached to this Affidavit as Exhibit 1 is a true and correct copy of a letter from
Carrie M. Lambert to Kodak’s counsel, dated December 22, 2005.
5. Attached to this Affidavit as Exhibit 2 is a true and correct copy of a letter from
Michael J. Summersgill to Carrie M. Lambert, dated December 30, 2005.
6. Attached to this Affidavit as Exhibit 3 is a true and correct copy of a letter from
Carrie M. Lambert to all Defendants’ counsel, dated January 4, 2006.
7. Attached to this Affidavit as Exhibit 4 is a true and correct copy of an e-mail
string between Carrie M. Lambert and Defendants’ counsel dated January 6 — January 9, 2006.
8. Attached to this Affidavit as Exhibit 5 is a true and correct copy of a letter from
Carrie M. Lambert to all Defendants’ counsel, dated January 9, 2006.
9. Attached to this Affidavit as Exhibit 6 is a true and correct copy of a letter from
Naikang Tsao to Carrie M. Lambert, dated January 10, 2006.
10. Attached to this Affidavit as Exhibit 7 is a true and correct copy of a letter from
Eric J. Ward to Ronald J. Schutz, dated January 13, 2006.
ll. Attached to this Affidavit as Exhibit 8 is a true and correct copy of a letter from
Naikang Tsao to Carrie M. Lambert, dated January 18, 2006.
12. Attached to this Affidavit as Exhibit 9 is a true and correct copy of a letter from
Carrie M. Lambert to all Defendants’ counsel, dated January 24, 2006.
13. Attached to this Affidavit as Exhibit 10 is a true and correct copy of a letter from
Ronald J. Schutz to Eric J. Ward, dated January 24, 2006.
14. Attached to this Affidavit as Exhibit 11 is a true and correct copy of a letter from
Eric J. Ward to Ronald J. Schutz, dated January 25, 2006.
szossvr 2

Case 1 :04-cv-01436-JJF Document 89 Filed 01 /26/2006 Page 3 of 4
15. Attached to this Affidavit as Exhibit 12 is a true and correct copy of Defendant
Eastman Kodak Company’s Response to Plaintiffs First Request for Production of Documents
dated July 25, 2005.
16. Attached to this Affidavit as Exhibit 13 is a true and correct copy of Defendant
Eastman Kodak Company’s Response to Plaintiffs Second Request for Production of
Documents dated November 28, 2005.
17. Attached to this Affidavit as Exhibit 14 is a true and correct copy of Defendant
Eastman Kodak Company’s Response to Plaintiffs First Set of Interrogatories dated July 25,
2005.
18. Attached to this Affidavit as Exhibit 15 is a true and correct copy of Defendant
Eastman Kodak Company’s Response to Plaintiffs Second Set of Interrogatories dated
November 28, 2005.
19. Attached to this Affidavit as Exhibit 16 is a true and correct copy of a letter fiom
Carrie M. Lambert to all Defendants’ counsel, dated January ll, 2006.
Dated: January 26, 2006
B6 % {
Patricia P. McG gle (No. 3126)
SEITZ, VAN OGTROP & GREEN
222 Delaware Avenue, Suite 1500
P.O. Box 68
Wilmington, DE 19899
(302) 888-0600
szossvi 3

Case 1:O4—cv-01436-JJF Document 89 Filed O1/26/2006 Page 4 of 4
CERTIFICATE OF SERVICE
I, Patricia P. McGonigle, Esquire, hereby certify that on this 26th day of January 2006, I
electronically filed the foregoing documents with the Clerk of Court using CM/ECF which will
send notification of such filing to counsel of record.
/s/ Patricia P. McGonigle
Patricia P. McGonigle (ID No. 3126)
[email protected]
51868 vl