Free Affidavit - District Court of Delaware - Delaware

Case 1:04—cv—01436-JJF Document 108 Filed 02/09/2006 Page 1 of 3
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., )
MATSUSHITA ELECTRIC INDUSTRLAL 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 FURTHER SUPPORT OF PLAINTIFF
ST. CLAIR’S MOTION FOR LEAVE TO FILE UNDER SEAL A SUPPLEMENTAL BRIEF
AND ATTACHMENT TO PLAINTIFF’S MOTION FOR AN ORDER COMPELLIN G
DEFENDANT EASTMAN KODAK COMPANY TO SUBSTANTIVELY RESPOND TO
PLAINTIFF’S OUTSTANDING DISCOVERY REQUESTS AND TO MOVE FORWARD
WITH OWNERSIHP-RELATED DISCOVERY IN THIS CASE
I, Patricia P. McGonigle, declare as follows:
1. 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. This Affidavit is submitted in further support of Plaintiff St. Clair’s Motion for
Leave to File Under Seal a Supplemental Brief and Attachment to Plaintiffs Motion for an
Order Compelling Defendant Eastman Kodak Company to Substantively Respond to Plaintiffs
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Case 1:O4—cv—O1436-JJF Document 108 Filed O2/O9/2006 Page 2 of 3
Outstanding Discovery Requests and to Move Forward with Ownership-Related Discovery in
this Case.
4. Attached to this Affidavit as Exhibit A is a true and correct copy correspondence
from Eric J. Ward to Ronald J. Schutz and Lani R. Miller dated January 13, 2006.
5. Attached to this Affidavit as Exhibit B is a true and correct copy of
correspondence from Ronald J. Schutz to Eric J. Ward dated January 24, 2006.
6. Attached to this Affidavit as Exhibit C is a true and correct copy of
correspondence from Eric J. Ward to Ronald J. Schutz dated January 25, 2006.
7. Attached to this Affidavit as Exhibit D is a true and correct copy of
correspondence from William P. DiSalvatore to Jake M. Holdreith dated December 3, 2004.
8. Attached to this Affidavit as Exhibit E is a true and correct copy of
correspondence from Becky R. Thorson to William P. DiSalvatore dated December 17, 2004.
Dated: February 9, 2006 K
M
atrici cGonigle (No. 3126)
SEITZ, AN OGTROP & GREEN
222 Delaware Avenue, Suite 1500
P.O. Box 68
Wilmington, DE 19899
(302) 888-0600
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Case 1:04—cv—01436-JJF Document 108 Filed 02/09/2006 Page 3 of 3
A CERTIFICATE OF SERVICE
I, Patricia P. McGonigle, Esquire, hereby certify that on this 9th day of February 2006, I
electronically filed the foregoing documents with the Clerk of Court using CM/ECF which will V
send notification of such filing to coimsel of record.
/s; Patri . ’ >X onigle
t 14%
1> mgm (rn NO. 3126)
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