`Case 6:12—cv—OO799—JRG Document 180-3 Filed 07/10/14 Page 1 of 2 Page|D #: 5304
`
`IN THE UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`
`TYLER DIVISION
`
`Case No. 12-CV-00799-LED
`
`INVENSYS SYSTEMS, INC.,
`
`Plaintiff,
`
`VS.
`
`EMERSON ELECTRIC CO. and
`
`MICRO MOTION INC., USA,
`
`Defendants,
`
`and
`
`MICRO MOTION INC., USA,
`
`Counterclaim-Plaintiff,
`
`VS.
`
`INVENSYS SYSTEMS, INC.,
`
`Counterclairn-Defendant.
`
`DECLARATION OF RICHARD MAGINNIS
`
`I, Richard Maginnis, declare as follows:
`
`1.
`
`I am an engineer at Micro Motion.
`
`I began working at Micro Motion on
`
`September 30, 199?.
`
`2.
`
`When I spoke with Micro Motion’s attorneys in November of 2012,
`
`I did not
`
`remember or appreciate that the work that had been done prior to my employment at Micro
`
`Motion involved digital signal processing to generate a drive signal.
`
`3.
`
`When I- met with Micro Motion’s attomeys again on April 22, 2014 to discuss
`
`upcoming depositions, I remembered certain aspects of the work that preceded my employment
`
`
`
`Case 6:12-cv-00799-JRG Document 180-3 Filed 07/10/14 Page 2 of 2 PageID #: 5305
`Case 6:12—cv—OO799—JRG Document 180-3 Filed 07/10/14 Page 2 of 2 Page|D #: 5305
`
`at Micro Motion.
`
`I did some subsequent investigation and located a schematic that predated my
`
`employment. The work in the schematic was performed at Micro Motion by Tony Pankratz (a
`
`Micro Motion employee) and Howard Derby (a former consultant for Micro Motion).
`
`4.
`
`I did not remember in November 2012 or thereafter, until
`
`I
`
`looked at
`
`the
`
`schematic in April of 2014, that Mr. Pankratz had knowledge of the digital work that Mr. Derby
`
`had done prior to November 1997.
`
`5.
`
`Mr. Pankratz is a mechanical engineer, not an electrical engineer.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Dated: July t_(), 2014
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