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DSC's Disclosure Team
January 18, 1999

Beginning of Legal Text

Via Telecopy; (214) 939-8787
Eric D, Pearson, Esq.
Sayles & Lidji, P,C,
1201 Elm Street, Suite 4400
Dallas, Texas 75270

Re: Cause No. 199-00596-97
DSC Communications Corporation v. Evan Brown

Dear Eric:

Pursuant to the Court's Order regarding DSC's Motion to Compel Interrogatory Responses and for Sanctions, Alcatel USA, Inc. f/k/a DSC Communications Corporation would like the following persons to be members of the Development Team for the purpose of receiving a full and complete disclosure of the Solution, and subsequently evaluating and taking the necessary steps to preserve and protect the Solution:

  1. Dan McMurray
  2. Mike McCarty
  3. Wayne Jones, Esq.
  4. Eric Pinker, Esq.
  5. Tim Loomis, Esq.
  6. Steve Levine, Esq.

As members of the disclosure team, these persons would be permitted to review the Solution, subject to the Court's confidentiality requirements.

While Alcatel has identified the above-named persons in a good faith effort to include all persons who Alcatel believes will need to have access to the Solution, Alcatel reserves the right to seek leave to designate additional persons to be members of the Alcatel Development Team.

Please contact my office by Wednesday, January 27, 1999 if Mr. Brown has an objection to the persons listed above.

End of Legal Text

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