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I would think it depends on the BIOS version you get.
If you are refering to the GA-P35-DS3L you would need to have the F8a BIOS installed:http://www.gigabyte.com.tw/Support/Motherboard/CPUSupport_Model.aspx?ProductID=2629
If the BIOS is earlier then you will need to flash it obviously. Depends on when the board was made and how many older ones your vendor had lying around.
If your board needs to be flashed, any early C2D processor will suffice for the initial boot, flash the BIOS and then put in your new CPU.
my board had the F7 BIOS and had no problems with an E8400 right out of the box, the F8a bios is not required