`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
`Case No. 6:12-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.,
`
`Counterclaim-Defendant.
`
`DECLARATION OF KADIE M. JELENCHICK
`
`I, Kadie M. Jelenchick, do hereby declare as follows:
`
`1.
`
`I am an attorney with the firm Foley & Lardner LLP, counsel for Emerson
`
`Electric Co. and Micro Motion, Inc. in the above-captioned matter. I submit this declaration in
`
`support of Emerson Electric Co.’s and Micro Motion, Inc.’s Opposed Motion to Amend Docket
`
`Control Order.
`
`2.
`
`Attached as Exhibit A is a true and correct copy of an email I sent to Invensys’s
`
`counsel, Mr. Jeffrey Johnson, dated November 3, 2014.
`
`4812-3751-6576.
`
`
`
`Case 6:12-cv-00799-JRG Document 244-1 Filed 11/26/14 Page 2 of 2 PageID #: 9327
`
`3.
`
`In the course of meeting and conferring to prepare the parties’ Joint Status Report,
`
`(Dkt. No. 241), on or around November 4-5, 2014, Invensys’s counsel, Ms. Claudia Frost,
`
`indicated to me and co-counsel that Invensys’s damages expert, Mr. W. Christopher Bakewell,
`
`would not be available for deposition during the entire month of November.
`
`4.
`
`Attached as Exhibit B is a true and correct copy of an email from Invensys’s
`
`counsel, Ms. Frost, to me and co-counsel, dated November 11, 2014.
`
`5.
`
`Attached as Exhibit C is a true and correct copy of an email I sent to Invensys’s
`
`counsel, dated November 19, 2014.
`
`6.
`
`Attached as Exhibit D is a true and correct copy of an email I sent to Invensys’s
`
`counsel, dated November 21, 2014.
`
`7.
`
`Attached as Exhibit E is a true and correct copy of an email I sent to Invensys’s
`
`counsel, dated November 24, 2014.
`
`8.
`
`Attached as Exhibit F is a true and correct copy of an email I sent to Invensys’s
`
`counsel, dated November 25, 2014.
`
`9.
`
`Attached as Exhibit G is a true and correct copy of an email from Invensys’s
`
`counsel, Ms. Dawn Jenkins, to me and co-counsel, dated November 21, 2014.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Dated: November 26, 2014
`
`Respectfully submitted,
`
`/s/ Kadie M. Jelenchick
`Kadie M. Jelenchick, WI Bar No. 1056506
`Foley & Lardner LLP
`777 East Wisconsin Avenue
`Milwaukee, Wisconsin 53202
`Phone: (414) 271-2400
`Fax: (414) 297-4900
`Email: kjelenchick@foley.com
`
`2
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
