Exhibit 2007
`
`Exhibit 2007
`
`
`
`Exhibit 2007
`
`
`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Michael J. Femal <MFemal@muchshelist.com>
`Tuesday, October 04, 2016 12:29 PM
`Alan Whitehurst; Kevin Chu; James Hanrath; 'Bennett, Norma'
`Quinn-PerDiem; 'Mark Mann'; 'Blake Thompson'
`RE: PerDiem v. GPS NA - de-designating portions of Lewis deposition transcript
`
`Alan,
`
`
`Pursuant to our call this morning, here is confirmation to go ahead and use these few designations as now non‐
`confidential from Todd Lewis deposition.
`
`
`Thanks,
`
`
`Mike
`
`
`
`Michael J. Femal
`Much Shelist, P.C.
`191 North Wacker Drive, Suite 1800
`Chicago, IL 60606
`Phone 312.521.2768
`Fax 312.521.2868
`MFemal@muchshelist.com
`Visit our website at www.muchshelist.com
`
`Member of Ally Law
`
`Please consider the environment before printing this email.
`
`The information contained in this email communication is intended only for the personal and confidential use of the designated recipient named above. This
`message may be an attorney-client communication, and as such is privileged and confidential. If the reader of this message is not the intended recipient, you are
`hereby notified that you have received this communication in error, and that any review, dissemination, distribution, or copying of the message is strictly prohibited.
`If you have received this transmission in error, please notify us immediately by telephone and/or reply email.
`
`From: Alan Whitehurst [mailto:alanwhitehurst@quinnemanuel.com]
`Sent: Tuesday, October 04, 2016 10:49 AM
`To: Kevin Chu; Michael J. Femal; James Hanrath; Bennett, Norma
`Cc: Quinn-PerDiem; 'Mark Mann'; Blake Thompson
`Subject: RE: PerDiem v. GPS NA - de-designating portions of Lewis deposition transcript
`
`
`Mike,
`
`
`Good talking with you this morning. Thank you for confirming that GPSNA agrees to de‐designate the Lewis transcript
`28:11‐29:6 and 38:10‐17 as nonconfidential.
`
`
`Best regards,
`
`
`Alan
`
`
`
`1
`
`
`
`From: Alan Whitehurst
`Sent: Monday, October 03, 2016 4:31 PM
`To: Kevin Chu <kevinchu@quinnemanuel.com>; 'Michael J. Femal' <MFemal@muchshelist.com>;
`''jhanrath@muchshelist.com' (jhanrath@muchshelist.com)' <jhanrath@muchshelist.com>; 'Bennett, Norma'
`<nbennett@mcfall‐law.com>
`Cc: Quinn‐PerDiem <Quinn‐PerDiem@quinnemanuel.com>; 'Mark Mann' <mark@themannfirm.com>; 'Blake Thompson'
`<blake@themannfirm.com>
`Subject: RE: PerDiem v. GPS NA ‐ de‐designating portions of Lewis deposition transcript
`
`
`Mike – Can you please get back to us where things stand? Thanks, Alan
`
`
`
`From: Alan Whitehurst
`Sent: Monday, October 03, 2016 11:31 AM
`To: Kevin Chu <kevinchu@quinnemanuel.com>; Michael J. Femal <MFemal@muchshelist.com>;
`'jhanrath@muchshelist.com' (jhanrath@muchshelist.com) <jhanrath@muchshelist.com>; Bennett, Norma
`<nbennett@mcfall‐law.com>
`Cc: Quinn‐PerDiem <Quinn‐PerDiem@quinnemanuel.com>; 'Mark Mann' <mark@themannfirm.com>; Blake Thompson
`<blake@themannfirm.com>
`Subject: RE: PerDiem v. GPS NA ‐ de‐designating portions of Lewis deposition transcript
`
`
`Mike – good talking with you just now. Here is the email that we sent you. This should be something that you and I can
`work out quickly. Please confirm by the end of the day that GPSNA will agree to de‐designate the Lewis transcript 28:11‐
`29:6 and 38:10‐17 as nonconfidential. Otherwise please let us know when you and Norma are available today to meet
`and confer. Best, Alan
`
`
`Dear Counsel,
`
`
`Pursuant to Paragraph 19 of the Stipulated Protective Order (Dkt. 36), we write to respectfully request de‐
`designation of the following portions of the deposition transcript of Todd Lewis: 28:11‐29:6, 38:10‐17.
`
`
`These passages discuss how GPS North America was merged with SkyBitz. PerDiem does not believe there is any
`good‐faith basis to treat this information as confidential, given that the merger of GPS North America and
`SkyBitz is already reflected in numerous public press releases available online. See, e.g.,
`http://www.skybitz.com/local‐fleets/news‐events/press‐releases/id/154/skybitz‐a‐telular‐company‐enters‐
`agreement‐to‐acquire‐reltima‐and‐gps‐north‐america (“SkyBitz®, the leader in remote asset tracking and
`information management solutions, today announced that it has entered into a definitive agreement to acquire
`Reltima and GPS North America . . .”) Because there is no good‐faith basis to treat this information as
`confidential, the passages at Lewis Dep. 28:11‐29:6 and 38:10‐17 should be de‐designated.
`
`
`Please let us know, by close of business tomorrow, whether you will agree to de‐designate these passages. If
`you do not agree to de‐designate these passages, please provide your position on why you believe these
`passages deserve confidentiality protection, so that PerDiem can accurately state your position when seeking
`relief from the Court.
`
`
`Best regards,
`Kevin
`
`
`
`
`
`2
`
`
`
`From: Alan Whitehurst
`Sent: Friday, September 30, 2016 4:16 PM
`To: Kevin Chu <kevinchu@quinnemanuel.com>; Michael J. Femal <MFemal@muchshelist.com>;
`'jhanrath@muchshelist.com' (jhanrath@muchshelist.com) <jhanrath@muchshelist.com>; Bennett, Norma
`<nbennett@mcfall‐law.com>
`Cc: Quinn‐PerDiem <Quinn‐PerDiem@quinnemanuel.com>; 'Mark Mann' <mark@themannfirm.com>; Blake Thompson
`<blake@themannfirm.com>
`Subject: RE: PerDiem v. GPS NA ‐ de‐designating portions of Lewis deposition transcript
`
`
`Mike -- any update on this? If not, please let me know if you are available to meet and confer on Monday at 10
`am Central. If that time does not work, please let me know a time on Monday that does. Best, Alan
`
`
`
`-------- Original message --------
`From: Alan Whitehurst <alanwhitehurst@quinnemanuel.com>
`Date: 9/28/16 5:55 PM (GMT-05:00)
`To: Kevin Chu <kevinchu@quinnemanuel.com>, "Michael J. Femal" <MFemal@muchshelist.com>,
`"'jhanrath@muchshelist.com' (jhanrath@muchshelist.com)" <jhanrath@muchshelist.com>, "Bennett, Norma"
`<nbennett@mcfall-law.com>
`Cc: Quinn-PerDiem <Quinn-PerDiem@quinnemanuel.com>, 'Mark Mann' <mark@themannfirm.com>, Blake
`Thompson <blake@themannfirm.com>
`Subject: RE: PerDiem v. GPS NA - de-designating portions of Lewis deposition transcript
`
`
`Mike – please confirm that GPSNA will agree to de‐designate. This should be something that we can agree on. Thanks,
`Alan
`
`
`
`From: Kevin Chu
`Sent: Tuesday, September 27, 2016 9:53 AM
`To: Michael J. Femal <MFemal@muchshelist.com>; 'jhanrath@muchshelist.com' (jhanrath@muchshelist.com)
`<jhanrath@muchshelist.com>; Bennett, Norma <nbennett@mcfall‐law.com>
`Cc: Quinn‐PerDiem <Quinn‐PerDiem@quinnemanuel.com>; 'Mark Mann' <mark@themannfirm.com>; Blake Thompson
`<blake@themannfirm.com>
`Subject: PerDiem v. GPS NA ‐ de‐designating portions of Lewis deposition transcript
`
`
`Dear Counsel,
`
`
`Pursuant to Paragraph 19 of the Stipulated Protective Order (Dkt. 36), we write to respectfully request de‐designation of
`the following portions of the deposition transcript of Todd Lewis: 28:11‐29:6, 38:10‐17.
`
`
`These passages discuss how GPS North America was merged with SkyBitz. PerDiem does not believe there is any good‐
`faith basis to treat this information as confidential, given that the merger of GPS North America and SkyBitz is already
`reflected in numerous public press releases available online. See, e.g., http://www.skybitz.com/local‐fleets/news‐
`events/press‐releases/id/154/skybitz‐a‐telular‐company‐enters‐agreement‐to‐acquire‐reltima‐and‐gps‐north‐america
`(“SkyBitz®, the leader in remote asset tracking and information management solutions, today announced that it has
`entered into a definitive agreement to acquire Reltima and GPS North America . . .”) Because there is no good‐faith
`basis to treat this information as confidential, the passages at Lewis Dep. 28:11‐29:6 and 38:10‐17 should be de‐
`designated.
`
`
`3
`
`
`
`Please let us know, by close of business tomorrow, whether you will agree to de‐designate these passages. If you do not
`agree to de‐designate these passages, please provide your position on why you believe these passages deserve
`confidentiality protection, so that PerDiem can accurately state your position when seeking relief from the Court.
`
`
`Best regards,
`Kevin
`
`
`This email has been scanned for email related threats and delivered safely by Mimecast.
`For more information please visit http://www.mimecast.com
`
`4
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