``Please take notice that on Feb 3rd 2005, at 3 PM, or soon thereafter as counsel may be heard before Magistrate Judge Howard R Lloyd of the US District Court, North District of CA.... ... plaintiff Patriot Scientific Corp will move for an Order (1) striking the Attorney`s Eyes Only provision of the Modified Protective Order; (2) compelling the production of an unredacted license aggreement; (3) compelling defendent Daniel E Leckrone to respond to questions asked during his deposition; and (4) compelling defendent Charles H Moore to produce documents``

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(1) Moore/ TPL`s attorneys have a box with ``over 3,000`` documents they have designated under the Modified Protective order including SEC docs, patent & PTO notices, correspondence from Patriot`s counsel, documents with addresses, e-mails, product data sheets... B&O accuses abuse of the order

(2) B&O want to see the entire Intel licensing agreement

(3) B&O wants Leckrone to answer questions he refused to during deposition, including.. The date, maker and recipient of any document that Leckrone believes indicates that Mr Higgins attempted to persuade third parties that Mr Fish made contributions to the `336 patent or its parent patent application when, in fact, he had not made the contributions.. When did Leckrone cease working with Moore to comercialize the Shboom chip?.. The author, recipient, and date of any document which Leckrone believes formally terminates his retainer agreement with Mr Fish... What company had an agreement with iTV which defendant Leckrone worked to ``unwind``?

(4) During deposition Moore indicated he may have floppy discs that contain design layouts of computer chips he designed, that contain elemants of the `336 patent. Patriot requested printouts of design layouts.. Counsel for Moore has refused to produce them, also stating some of the discs may now be unreadable.. ``In short, they will confirm that, regrettably Moore has chosen not to tell the truth about the identity of the inventor who conceived the patent (in a proposterous recitation, Moore conceded that he concieved all the claims of one related patent and, after conferring with counsel, changed his general approach to testify that all the numerous claims in other related patents were jointly concieved by both inventors without one of them having an original idea)``