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FILED: NEW YORK COUNTY CLERK 09/01/2020 05:50 PM
`FILED: NEW YORK COUNTY CLERK 09/01/2020 05:50 PM
`NYSCEF DOC. NO. 117
`NYSCEF DOC. NO. 117
`
`INDEX NO. 190344/2018
`INDEX NO. 190344/2018
`RECEIVED NYSCEF: 09/01/2020
`RECEIVED NYSCEF: 09/01/2020
`
`
`
`
`
`
`
`EXHIBIT 8
`EXHIBIT 8
`
`

`

`FILED: NEW YORK COUNTY CLERK 09/01/2020 05:50 PM
`NYSCEF DOC. NO. 117
`
`INDEX NO. 190344/2018
`
`RECEIVED NYSCEF: 09/01/2020
`
`Jacobs, Erik
`
`Genevieve MacSteel
`
`Penka Nikolova-Baltov; Clinton, Benjamin
`
`RE: Eaton USJMs
`
`Tuesday, February 5, 2019 3: 08: 25 PM
`
`From:
`To:
`Cc:
`Subject:
`Date:
`
`Gen,
`
`To be a bigger pain … these three cases are “ship records” cases.
`
`Your office should have been served with PID interrogatories – please answer them and let us know
`
`what you know about whether your equipment was on the respective ships of these men.
`
`We have to reason to believe that it is.
`
`Erik
`
`From: Genevieve MacSteel [mailto:gmacsteel@deybllp.com]
`
`Sent: Tuesday, January 29, 2019 3:58 PM
`
`To: Jacobs, Erik
`
`Cc: Penka Nikolova-Baltov
`
`Subject: Eaton USJMs
`
`Hi Erik:
`
`Sorry to be a pain, but I was wondering whether you would agree to sign off on these USJMs for Cutler Hammer as
`
`there was no ID at the depositions. If you are not inclined to sign the USJM, can you let me know the basis for not
`
`signing, as there was no product identification. Any questions, please feel free.
`
`Thanks and as always appreciate it!
`
`Genevieve
`
`Genevieve MacSteel
`
`Darger Errante Yavitz & Blau LLP
`
`116 East 27th Street, 12th Floor
`
`New York, New York 10016
`
`Main: 212.452.5300
`
`Direct: 212.452.5305
`
`gmacsteel@deybllp.com
`
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`

`

`FILED: NEW YORK COUNTY CLERK 09/01/2020 05:50 PM
`NYSCEF DOC. NO. 117
`
`INDEX NO. 190344/2018
`
`RECEIVED NYSCEF: 09/01/2020
`
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