`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
`Case No. 6:12-cv-00799-LED
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`INVENSYS SYSTEMS, INC.,
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`Plaintiff,
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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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`and
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`MICRO MOTION INC., USA,
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`Counterclaim-Plaintiff,
`
`vs.
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`INVENSYS SYSTEMS, INC.,
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`Counterclaim-Defendant.
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`DECLARATION OF KADIE M. JELENCHICK
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`I, Kadie M. Jelenchick, do hereby declare as follows:
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`1.
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`I am an attorney with the firm Foley & Lardner LLP, and one of the attorneys for
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`Defendant Emerson Electric Co. (“Emerson”) in the above-captioned matter. I am a member in
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`good standing of the Bar of the State of Wisconsin and am admitted in this District. I am over
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`the age of 18, competent, and if called to testify to the contents of this declaration, would do so
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`truthfully. I submit this declaration in accordance with 28 U.S.C. § 1746(2) and in support of
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`Emerson’s Notice Regarding Deadline for Reply in Support of Its Motion for Summary
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`Judgment.
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`2.
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`Attached as Exhibit 1 is a true and correct copy of a January 14, 2014 email I
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`received from Claudia Frost, counsel for Invensys Systems, Inc. (“Invensys”), that provides the
`4817-4459-2664.1
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`
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`Case 6:12-cv-00799-JRG Document 97-1 Filed 01/20/14 Page 2 of 2 PageID #: 2577
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`identity of the customer discussed in Invensys’s response to Emerson’s motion for summary
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`judgment, which was designated “Outside Counsel Eyes Only.”
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`3.
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`Attached as Exhibit 2 is a true and correct copy of a January 15, 2014 email I sent
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`to Ms. Frost, challenging the “Outside Counsel Eyes Only” designation.
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`4.
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`Attached as Exhibit 3 is a true and correct copy of a January 16, 2014 email I
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`received from Dawn Jenkins, counsel for Invensys, that re-designates the customer name as
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`“Confidential.”
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Dated: January 20, 2014
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`Respectfully submitted,
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`/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
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`4817-4459-2664.1
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`2