Free Response to Motion - District Court of Delaware - Delaware

Case 1 :04-cv—00960-SLR Document 95-3 Filed 03/13/2006 Page1 014
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Case 1 :04-cv—00960-SLB Document 95-3 Filed 03/13/2006 Page 2 of 4
Cates, Emily
From: Bellew, Sean [[email protected]]
Sent: Tuesday, February 21, 2006 7:16 PM
To: Cates, Emily; Felice, David A.
Cc: Talbot, Cory; Papetti, Randy; Bowser, William; Patrick, SherryAnn; Berry, Kevin F.
Subject: RE: J—Squared v. Motorola - Draft of Motion to Compel
Emily —
Sorry for the delay in getting back to you. I was out for the holiday yesterday
and am just getting a chance to respond to your e-mails.
We intend to file the Motion. These issues have been outstanding for some time
now, and the courtesy of granting Motorola additional time to address them is likely to
prejudice our clients —- which has been the case with previous courtesies. We will file
the Motion, but we invite a response from Motorola to avoid the Court having to decide the
Motion. If an agreement is reached after the Motion is filed, we can simply withdraw it
at that point.
Feel free to call me if you would like to discuss.

From: Cates, Emily [mailto:[email protected]]
Sent: Tue 2/21/2006 7:33 PM
To: Felice, David A.; Bellew, Sean
Cc: Talbot, Cory; Papetti, Randy; Bowser, William; Patrick, SherryAnn
Subject: RE: J—Squared v. Motorola — Draft of Motion to Compel
Sean and David,
I haven't heard back from you in response to my e—mail below. As I indicated, Randy and
Cory are out of the office most of the week.
Accordingly, we will get you our response on Friday. Thank you.
Emily
—-——— Original Message —-———
From: Cates, Emily
Sent: Monday, February 20, 2006 4:15 PM
To: ’Felice, David A.‘; Bellew, Sean
Cc: Talbot, Cory; Papetti, Randy; Bowser, William; Patrick, SherryAnn
Subject: RE: J—Squared v. Motorola — Draft of Motion to Compel
Sean and David,
We received your draft motion to compel. We are looking into the issues you raised and
ask that you give us until Friday to respond, as Randy and Cory are out of the office most
of the week. Let me know. Thank you.
Emily
~——-— Original Message —————
From: Felice, David A. [mailto:[email protected]]
Sent: Friday, February 17, 2006 5:04 PM
To: Cates, Emily
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Case 1 :04-cv—00960-SLR Document 95-3 Filed 03/13/2006 Page 3 of 4
Cc: Talbot, Cory; Papetti, Randy; Bowser, William; Bellew, Sean
Subject: J—Squared v. Motorola — Draft of Motion to Compel
Emily:
Pursuant to D. Del. LR 7.1, we are providing you with a draft copy of Plaintiffs' motion
to compel. A final version of this motion may have revisions, but the requested documents
and information should remain the same.
Please review this motion to determine whether Motorola will voluntarily produce the
documents and/or information requested. Please provide me with your response by Wednesday
at 4:00 pm EST. Thank you and have a good weekend.
David
David A. Felice
Cozen O'Connor
1201 North Market Street
Wilmington, Delaware 19801
302-295-2011 (voice)
866-776-8911 (direct fax)
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