`Case 6:12—cv—00799—JRG Document 247-1 Filed 12/03/14 Page 1 of 2 Page|D #: 9389
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`EXHIBIT A
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`EXHIBIT A
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`Case 6:12-cv-00799-JRG Document 247-1 Filed 12/03/14 Page 2 of 2 PageID #: 9390
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`Johnson, Jeffrey
`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Johnson, Jeffrey
`Friday, October 10, 2014 6:50 PM
`LHansen@foley.com
`Frost, Claudia
`Invensys v Emerson - Expedited Briefing
`
`Linda,
`
`Thank you for your quick response on the expedited briefing issue.
`
`We propose two changes to your schedule. First, moving up the Reply and SurReply by one business day:
`
`Response – Oct. 20
`Reply – Oct. 22
`SurReply – Oct. 24
`
`Second, we do not believe we need to move the expert deadlines at this time. However, we are willing to move the
`rebuttal reports back by a week to Nov. 26 or back 12 days to Dec. 1, if that helps you now. Even with that move, we do
`not believe any of the other deadlines need be moved at this time. There will be plenty of time to get in the few expert
`depositions. We do not want to push into or past the holidays on any of the deadlines at this time. Obviously, if more time
`becomes necessary, we can deal with that when as needed.
`
`If that is ok with you, then we will prepare an agreed expedited briefing schedule to submit.
`
`In addition, please secure dates for your rebuttal experts sometime between Dec. 10 and 19 for their deposition now. Let
`us know if and when you want to depose our rebuttal experts and we will do the same. Securing them now in October
`should avoid any last minute issues. Further, if you are going to want to depose Manus Henry before your rebuttal report,
`please give a range of dates as soon as possible given the logistics needed for such a deposition. Please also provide
`dates for Tamal Bose and Harry Direen during the week of Nov. 10.
`
`Thanks,
`Jeffrey
`
`Jeffrey Johnson
`Partner
`
` T
`
` +1 713.425.8445
`F +1 713.300.6045
`M +1 832.866.8702
`E jeffrey.johnson@dlapiper.com
`
`
`
`
`DLA Piper LLP (US)
`1000 Louisiana Street, Suite 2800
`Houston, Texas 77002-5005
`United States
`www.dlapiper.com
`
`
`1
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