Case 6:12-cv-00799-JRG Document 244-6 Filed 11/26/14 Page 1 of 6 PageID #: 9346
`Case 6:12—cv—00799—JRG Document 244-6 Filed 11/26/14 Page 1 of 6 Page|D #: 9346
`
`EXHIBIT E
`
`EXHIBIT E
`
`
`
`

`
`Case 6:12-cv-00799-JRG Document 244-6 Filed 11/26/14 Page 2 of 6 PageID #: 9347
`
`From:
`To:
`Cc:
`
`Subject:
`Date:
`
`Jelenchick, Kadie M.
`Jenkins, Dawn
`Frost, Claudia; Costakos, Jeffrey N.; Johnson, Jeffrey; Stewart, Courtney; Guy Harrison; Hansen, Linda E.B.;
` Service-Invensys Coriolis; Berta, Jason A.; Moran, Michelle A.
`RE: Follow up
`Monday, November 24, 2014 10:05:00 PM
`
`Claudia and Dawn:
`
` I
`
` am following up on the below.
`
`
`We would like to discuss Mr. Bakewell’s availability for deposition and the deadline change for our
` rebuttal report. Given the holiday and the short week, let’s find a convenient time for us to talk
` about these issues as well as the subpoena to Mr. Bakewell tomorrow, Tuesday. Please let us know
` when you are available.
`
`Also, Claudia, I understand from Guy that you may want copies of some of the materials relating to
` Emerson’s corporate structure, which we provided for inspection last week. We can discuss this
` tomorrow too.
`
`Thanks and have a good evening,
`Kadie M. Jelenchick
`Foley & Lardner LLP
`777 East Wisconsin Avenue
`Milwaukee, Wisconsin 53202
`414.319.7324
`kjelenchick@foley.com
`
`From: Jelenchick, Kadie M.
`Sent: Friday, November 21, 2014 5:46 PM
`To: 'Jenkins, Dawn'
`Cc: Frost, Claudia; Costakos, Jeffrey N.; Johnson, Jeffrey; Stewart, Courtney; Guy Harrison; Hansen,
` Linda E.B.; Service-Invensys Coriolis; Berta, Jason A.; Moran, Michelle A.
`Subject: RE: Follow up
`
`Dawn:
`
`Monday is fine for the response to the subpoena.
`
`We look forward to hearing back from you regarding the other issues.
`
`Thanks,
`
`Kadie M. Jelenchick
`Foley & Lardner LLP
`777 East Wisconsin Avenue
`Milwaukee, Wisconsin 53202
`414.319.7324
`
`

`
`Case 6:12-cv-00799-JRG Document 244-6 Filed 11/26/14 Page 3 of 6 PageID #: 9348
`
`kjelenchick@foley.com
`
`From: Jenkins, Dawn [mailto:Dawn.Jenkins@dlapiper.com]
`Sent: Friday, November 21, 2014 5:17 PM
`To: Jelenchick, Kadie M.
`Cc: Frost, Claudia; Costakos, Jeffrey N.; Johnson, Jeffrey; Stewart, Courtney; Guy Harrison; Hansen,
` Linda E.B.; Service-Invensys Coriolis; Berta, Jason A.; Moran, Michelle A.
`Subject: Re: Follow up
`
`Dear Kadie:
`
`Thank you for this information.
`
`We are conferring with Mr. Bakewell regarding his schedule and will discuss his availability
` with you next week.
`
`Regarding the subpoena to Mr. Bakewell for which we accepted service, we need a few more
` days to respond. Mr. Bakewell has been in trial this week. We would like to take the
` weekend and try to send you a response on Monday. Please let me know if that is acceptable.
`
`Best regards,
`Dawn
`
`Sent from my iPhone
`
`On Nov 21, 2014, at 4:46 PM, "KJelenchick@foley.com" <KJelenchick@foley.com> wrote:
`
`Hi Claudia:
`
`Attached please find the sales information for the 2200S and 9739MVD products,
` which is branded with production numbers MM1212770-71 and designated
` RESTRICTED – ATTORNEYS’ EYES ONLY. We are still pulling together the 700 data and
` will get that to you as soon as we can.
`
`Also, we haven’t heard from you regarding Mr. Bakewell’s deposition or the new
` deadline for our rebuttal report. Please let us know when we can expect to hear back
` from you on this.
`
`Thanks and have a good weekend,
`Kadie M. Jelenchick
`Foley & Lardner LLP
`777 East Wisconsin Avenue
`Milwaukee, Wisconsin 53202
`414.319.7324
`kjelenchick@foley.com
`
`From: Jelenchick, Kadie M.
`Sent: Wednesday, November 19, 2014 10:25 AM
`To: 'Frost, Claudia'
`
`

`
`Case 6:12-cv-00799-JRG Document 244-6 Filed 11/26/14 Page 4 of 6 PageID #: 9349
`
`Cc: Costakos, Jeffrey N.; Johnson, Jeffrey; Stewart, Courtney; Guy Harrison; Linda E. B.
` Hansen (LHansen@foley.com)
`Subject: RE: Follow up
`
`Hi Claudia:
`
` I
`
` wanted to give you an update on the timing for the production of email and 700 core
` processor sales information. With respect to email, we anticipate producing the non-
`privileged hits from the search strings outlined in our July 30 Email Report no later than
` Wednesday, November 26. With respect to the sales information, we anticipate
` producing 700 core processor revenue and units (by fiscal year and sensor type) on
` Friday, November 21.
`
`Also, I wanted to revisit scheduling Mr. Bakewell’s deposition. You indicated that he is
` available the week of December 15. Please confirm the date and place where you will
` be making him available. Given that Mr. Bakewell isn’t being made available until the
` week of December 15, and our responsive report is currently due December 5, as we
` discussed last week at the hearing, we would like to move our deadline back. We
` propose Tuesday, December 23, with depositions to be the week of January 5, which is
` two weeks before any Daubert letter motions are due. Please let us know.
`
`Thanks,
`Kadie M. Jelenchick
`Foley & Lardner LLP
`777 East Wisconsin Avenue
`Milwaukee, Wisconsin 53202
`414.319.7324
`kjelenchick@foley.com
`
`From: Frost, Claudia [mailto:Claudia.Frost@dlapiper.com]
`Sent: Tuesday, November 18, 2014 3:38 PM
`To: Jelenchick, Kadie M.
`Cc: Costakos, Jeffrey N.; Johnson, Jeffrey; Stewart, Courtney; Guy Harrison
`Subject: Re: Follow up
`
`Dear Kadie and Guy,
`Thank you for your email.
`We will inspect the customer list at Guy's office on Friday. I will provide a more
` precise time as we get closer.
`Thank you,
`Claudia
`
`Sent from my BlackBerry 10 smartphone.
`From: KJelenchick@foley.com
`Sent: Friday, November 14, 2014 7:22 PM
`To: Frost, Claudia
`Cc: JCostakos@foley.com; Johnson, Jeffrey; Stewart, Courtney; Guy Harrison
`
`

`
`Case 6:12-cv-00799-JRG Document 244-6 Filed 11/26/14 Page 5 of 6 PageID #: 9350
`
`Subject: Re: Follow up
`
`Hi Claudia:
`
`Wednesday is fine for the customer list inspection at Guy's office. However, Guy
` is only available from 9 am until noon. If Friday is workable for you, Guy is
` available all day.
`
`I will circle back to you next week on the timing for the production of the email
` and sales data.
`
`Thanks and have a good weekend.
`
`Kadie M. Jelenchick
`Foley & Lardner LLP
`777 East Wisconsin Avenue
`Milwaukee, WI 53202
`414.319.7324
`kjelenchick@foley.com<mailto:kjelenchick@foley.com>
`
`On Nov 13, 2014, at 7:00 PM, Frost, Claudia
` <Claudia.Frost@dlapiper.com<mailto:Claudia.Frost@dlapiper.com>> wrote:
`
`Dear Kadie:
`
`I am following up on a few items.
`
`Can you please give me your best estimate as to when the 9739 MVD and 2200 S
` data will be provided and the precise form it will be in. Likewise, please provide
` me the same estimate and description for the 700 puck data.
`
`I will be able to go to Longview next Wednesday to review the customer list.
` Please confirm that it will be in Guy’s office then and he can accommodate me at
` that time.
`
`Finally, please let me know when you expect the email production that you agreed
` to provide per the joint status report will be produced.
`
`Many thanks,
`
`Claudia
`
`Claudia Wilson Frost
`Partner
`
`T +1 713.425.8450
`F +1 713.300.6050
`M +1 832.814.6322
`E claudia.frost@dlapiper.com <mailto:claudia.frost@dlapiper.com>
`
`

`
`Case 6:12-cv-00799-JRG Document 244-6 Filed 11/26/14 Page 6 of 6 PageID #: 9351
`
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