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Case 1 :04-cv—00876-GIVIS Document 332 Filed 04/19/2007 Page 1 of 2
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ATTORNEYS AND COUNSELLORS AT LAW TELEPHONE
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April 19, 2007
The Honorable Gregory M. Sleet VIA ELECTRONIC FILING
United States District Court
844 King Street .
Wilmington, Delaware 19801
Re: T elcordia Technologies, Inc. v. Lucent Technologies, Inc.,
C.A. No. 04-875-GMS
T elcordio Technologies, Inc. v. Cisco Systems, Inc.,
C.A. No. 04-876-GMS
Dear Judge Sleet:
I am writing to provide the parties’ joint proposed agenda for the teleconference with the
Court that has been scheduled for 2:00 p.m. tomorrow, April 20, 2007, in the above actions:
Telc0rdia's Issues:
In connection with former France Telecom employee Thierry Houdoin: (i) whether
defendants have complied with the Court's instruction at the pretrial conference to make their
best efforts to secure his attendance at a deposition prior to trial, and (ii) whether the witness
should be permitted to testify at trial if he declines to sit for a deposition prior to trial.
Attached for the Court’s review are copies of all communications between counsel and
Mr. Houdoin since the pretrial conference.
Defendants’ Issues:
(l) Defendants disagree with Telcordia's argumentative and inaccurate statement of
the issue concerning Mr. Houdoin. Defendants requested this conference because Mr. Houdoin
would like to know whether, if he were to agree to travel to the United States for trial, he would
also be requested to appear for a deposition.
(2) Plaintiffs submission last Friday of the supplemental report of its expert, Dr.
Clark, containing new opinions, and its refusal to make Dr. Clark available for his deposition.

Case 1 :04-cv—00876-GIVIS Document 332 Filed 04/19/2007 Page 2 of 2
The Honorable Gregory M. Sleet
April 19, 2007
Page 2
Respectfully,
/s/ Steven J Bczlick
Steven J. Balick
SJ B/dmf
Attachment
179834.1
cc: Donald R. Dunner, Esquire (via electronic mail; vv/attachment)
John W. Shaw, Esquire (by hand, and via electronic mail; vv/attachment)
Steven C. Chemy, Esquire (via electronic mail; w/ attachment)
David A. Nelson, Esquire (via electronic mail; w/attachment)
Jack B. Blumenfeld, Esquire (by hand, and via electronic mail; vv/attachment)
Edward R. Reines, Esquire (via electronic mail; vv/attachment)