Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-01338-JJF Document 552-2 Filed O9/13/2006 Page1 of 3 A
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z September 6, 20(lh
·` Robert J- Benson, Esq. -· V ` Via Facsimile _ l
__ Hogan & H artson L.L.P.
` · 1999 Avenue ofthe Stars, Suite 1400 .
_ _ Los Angeles, CIA 90067
· Re: Honeywell LCD
_ Our File No. 019896-0229
Dear Mr. Benson;
Based on the statements in your letter of September 6, 2006, it is clear that SEC gathered
the documents Honeywell requested regarding SEC's LCD modules long ego. Despite that, SBC
has yet to produce n single document. According to your letter, SEC new has to undertake the
"uedious" task ofroviewiug the documents that have already been collected to segregate those _
documents that relate to the modules that Honeywell has specitlually identified. Your position xs
_ untenable.
_ T First, there is no need to seg; egute the documents. Since SEC has already completed the
` task of compiling the requested documents for all of SEC‘s LCD modules, all of these documents .
should be produced immediately. Both parties would save substantial time and money if all of
the documents are produced at this time.
In addition, your admission that SEC has already compiled the requested documents
completely undermines your assertions to both Honeywell and the Court that SEC could not _
figure out thc scope of this case. Clearly, SEC had no problem understanding IIoueywe1l’s
discovery requests, since it was able to provide the wquested documents to your firm. At a
~ mimmum, there is no basis on which SEC ooizld not have already produced documents regarding _
those LCD modules Honcyw ell identified in the early stages of this lawsuit. -
V Finally, you now indicate that SEC! will only produce as many documents as possible by
_ September 30, and that you willcominue to produce documents un a rolling basis thereafter.
This is unacceptable. To maintain tln: deadlines under the current Scheduling Order, Honeywell
must have complete productions no later than September 30, particularly since you now indicate
that many ofthe documents are not in English. Honeywell must have sullicient time to translate
and review the documents before it can begin scheduling depositions. Since SEC has already
(completed the task of collecting the documents, there is nn reason why the production cannot be c
completed by September 30. : y
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Robert J. Benson, Esq.
3. September 6, 2006
g Page 2
‘ " · Regards,
W ROBTNS, ICAPLAN, MILLER & CIR HSI L.L.P.
(I I ~ .
Denise S. Rahme
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_ Mrs zo: esm.1 U
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- 11113
Received Sen-U?-116 116:55 From-612 339 4181 To Hunan & Hartscn LLP Pan