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`IN THE UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
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`Case No. 6:12-cv-00799
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`Plaintiff,
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`Invensys Systems, Inc.,
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`vs.
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`Emerson Electric Co. and
`Micro Motion Inc., USA,
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`Defendants.
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`DECLARATION OF LINDA E.B. HANSEN IN SUPPORT OF
`EMERSON ELECTRIC CO.’S MOTION FOR
`SUMMARY JUDGMENT OF NONINFRINGEMENT
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`I, Linda E.B. Hansen, do hereby declare as follows:
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`1. I am I am a partner at Foley & Lardner LLP and one of the attorneys for Emerson
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`Electric Co. in this matter. I am over 18 years of age, of sound mind, and capable of
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`making this declaration.
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`2. Attached to this declaration as Exhibit A is a true and correct copy of an e-mail that I sent
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`to Nick Papastavros, counsel for Invensys, on December 12, 2012, asking if Invensys
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`would voluntarily dismiss this matter as against Emerson Electric Co.
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`3. Attached to this declaration as Exhibit B is a true and correct copy of an e-mail sent to me
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`by Nick Papastavros, counsel for Invensys, on December 21, 2012, indicating that
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`Invensys would not voluntarily dismiss this matter as against Emerson Electric Co.
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`4. Attached to this declaration as Exhibit C is a true and correct copy of another e-mail that
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`I sent to Nick Papastavros, counsel for Invensys, asking if Invensys would voluntarily
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`dismiss this matter as against Emerson Electric Co. It was sent on March 18, 2013.
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`4840-7762-1528.1
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`Case 6:12-cv-00799-JRG Document 106-2 Filed 01/31/14 Page 2 of 2 PageID #: 2699
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`5. Attached to this declaration as Exhibit D is a true and correct copy of an e-mail sent to
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`me by Chris Richart, counsel for Invensys, on behalf of Nick Papastavros on March 29,
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`2013. It indicated that Invensys would not voluntarily dismiss this matter as against
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`Emerson Electric Co., and that Invensys was entitled to discovery on the issue.
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`6. At no time has Invensys served a discovery request on Emerson regarding this issue.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed on January 31, 2014.
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`s/ Linda E.B. Hansen
`Linda E.B. Hansen
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`4840-7762-1528.1
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`2