2:12-md-02311-MOB-MKM Doc # 1276-3 Filed 03/31/16 Pg 1 of 21 Pg ID 22327
`2:12-md—O2311—MOB—MKM DOC # 1276-3 Filed O3/31/16 Pg 1 Of 21
`Pg ID 22327
`
`Exhibit G
`
`

`
`2:12-md-02311-MOB-MKM Doc # 1276-3 Filed 03/31/16 Pg 2 of 21 Pg ID 22328
`2:12-md—O2311—MOB—MKM DOC # 1276-3 Filed O3/31/16 Pg 2 Of 21
`Pg ID 22328
`
`Gangnes, Larry
`
`From:
`
`Sent:
`To:
`
`Cc:
`Subject:
`
`All:
`
`Yeager, Judy <Judy.Yeager@delphi.com> on behalf of Papelian, Joseph E
`<joseph.e.papelian@delphi.com> _
`Wednesday, January 21, 2015 8:34 AM
`vick@cuneolaw.com; Gangnes, Larry; b|ondon@fklmlaw.com;
`wburns@susmangodfrey.com; Davis, Kenneth R.; oochoa@susmangodfrey.com
`Frantangelo, Barbara K; Gruber, Douglas R
`Call regarding Delphi
`
`Thursday, February 5"‘ starting at 11:00 am until 2:00 pm coordinates with the requests below and the Delphi
`participants. This will be held at the Delphi Office, 5725 Delphi Dr., Troy MI 48098.
`I will transmit a meeting notice to
`add to your calendars.
`Regards,
`
`Judy on behalf ofJoe Papelian
`
`Judy Yeager
`Delphi Legal — Litigation
`5725 Delphi Drive
`MC: 483.400.5554
`
`Troy MI 48098
`'udy.yeager@de|phi.com
`1.248.813.2106 (Office)
`1.248.813.1122 (Fax)
`
`From: Vicky Romanenko [mailto:Vicky@cuneolaw.com]
`Sent: Thursday, January 15, 2015 4:18 PM
`To: Gangnes, Larry; Papelian, Joseph E; Yeager, Judy
`Cc: Billy London (b|ondon@fk|m|aw.com); Omar Ochoa (OOchoa@susmangodfrey.com); Warren T. Burns; Frantangelo,
`Barbara K; Davis, Kenneth R.; Yeager, Judy
`Subject: RE: Call regarding Delphi
`
`We are available February 4 and 5. We would like to propose that we begin at 11 am, ET.
`
`Joe, can you also give us an idea of the likely duration of the meeting?
`
`We continue to believe that it is important for us to understand what data and documents Delphi has, in order for us to
`continue our negotiations.
`If Delphi would prefer not to schedule a call before the meeting then we ask that you
`provide us with this information via correspondence or at the meeting.
`
`From: Gangnes, Larry [mailto:GangnesL@LanePowel|.com]
`Sent: Thursday, January 15, 2015 11:20 AM
`To: Papelian, Joseph E; Vicky Romanenko; Yeager, Judy
`Cc: Billy London (b|ondon@fklm|aw.com); Omar Ochoa (OOchoa@susmangodfrey.com); Warren T. Burns; Frantangelo,
`Barbara K; Davis, Kenneth R.; Yeager, Judy
`Subject: RE: Call regarding Delphi
`
`We are available the week of Feb. 2.
`
`

`
`2:12-md-02311-MOB-MKM Doc # 1276-3 Filed 03/31/16 Pg 3 of 21 Pg ID 22329
`2:12-md—O2311—MOB—MKM DOC # 1276-3 Filed O3/31/16 Pg 3 Of 21
`Pg ID 22329
`
`From: Papelian, Joseph E [mailto:joseph.e.pape|ian@delphi.com]
`Sent: Tuesday, January 13, 2015 9:14 AM
`To: Vicky Romanenko; Gangnes, Larry; Yeager, Judy
`Cc: Billy London (blondon@fklmlaw.com); Omar Ochoa (OOchoa@susmangodfrey.com); Warren T. Burns; Frantangelo,
`Barbara K; Davis, Kenneth R.; Yeager, Judy
`Subject: RE: Call regarding Delphi
`
`Vicky:
`
`The week of Feb 9 is not good for me except maybe Monday, Feb 9.
`
`i have mediation in LA later that week.
`
`Our plan is to assemble a pricing package on a Toyota program and review that with the group at a meeting to
`be scheduled.
`
`Joe
`
`From: Vicky Romanenko [mai|to:Vicky@cuneolaw.com]
`Sent: Tuesday, January 13, 2015 12:01 PM
`To: Papelian, Joseph E; Gangnes, Larry; Yeager, Judy
`Cc: Billy London (b|ondon@fk|m|aw.com); Omar Ochoa (OOchoa@susmangodfrey.com); Warren T. Burns; Frantangelo,
`Barbara K; Davis, Kenneth R.; Yeager, Judy
`Subject: RE: Call regarding Delphi
`
`Joe,
`
`We will check with our groups and circle back as to the first week of February. Are you available the second week of
`February as well?
`
`We don't mind foregoing a call this week, but we would like to schedule a call to follow up on last week's call, sometime
`before the meeting, so that we can get a better sense of what types of data and documents Delphi has, and what time
`period is covered. This will enable us to have a more informed discussion with you about what kind of production we
`can agree to. Are you available next week?
`
`From: Papelian,Joseph E [mailto:joseph.e.papel2ian@2delphi.com]
`Sent: Tuesday, January 13, 2015 7:51 AM
`To: Vicky Romanenko; Gangnes, Larry; Yeager, Judy
`Cc: Billy London (blondon@fklmlaw.com); Omar Ochoa (OOchoa@susmangodfrey.com); Warren T. Burns; Frantangelo,
`Barbara K; Davis, Kenneth R.; Yeager, Judy
`Subject: RE: Call regarding Delphi
`
`Vicky:
`
`i think the better approach is for us to prepare the presentation and schedule a date for us to meet the first
`week of February. Unfortunately, the key business folks are scheduled to be out of the country on business
`the last week of January. You can propose dates in the first week of February to Judy Yeager (my AdMin) who
`will circulate a meeting date. We will host the meeting at Delphi in Troy and open a line for those who cannot
`join in person.
`
`Thanks,
`
`Joe
`
`

`
`2:12-md-02311-MOB-MKM Doc # 1276-3 Filed 03/31/16 Pg 4 of 21 Pg ID 22330
`2:12-md—O2311—MOB—MKM DOC # 1276-3 Filed O3/31/16 Pg 4 Of 21
`Pg ID 22330
`
`From: Vicky Romanenko [mailto:Vicky@cuneolaw.com]
`Sent: Monday, January 12, 2015 9:09 PM
`To: Papelian, Joseph E; Gangnes, Larry; Yeager, Judy
`Cc: Billy London (blondon@fk|mlaw.com); Omar Ochoa (OOchoa@susmangodfrey.com); Warren T. Burns; Frantangelo,
`Barbara K; Davis, Kenneth R.
`Subject: RE: Call regarding Delphi
`
`We will check with our groups and circle back as to the date.
`
`We would like to have the call go forward as well, but have conflicts at 11:30 am ET.
`
`Are folks available on Thursday?
`
`From: Papelian, Joseph E [mailto:joseph.e.pape|ian@lcielphi.com]
`Sent: Monday, January 12, 2015 5:19 PM
`To: Gangnes, Larry; Vicky Romanenko; Yeager, Judy
`Cc: Billy London (blondon@fk|m|aw.com); Omar Ochoa (OOchoa@susmangodfrey.com); Warren T. Burns; Frantangelo,
`Barbara K; Davis, Kenneth R.
`Subject: RE: Call regarding Delphi
`
`Larry:
`
`I appreciate that Jan 29 would be a good date, but the key business folks will be out of the country. We’re
`looking at the following week. Please let me know if that works.
`
`Thanks,
`
`Joe
`
`‘From: Gangnes, Larry [mailto:OangnesL@LanePowel|.com]
`Sent: Monday, January 12, 2015 3:57 PM
`To: Papelian, Joseph E; Vicky Romanenko; Yeager, Judy
`Cc: Billy London (blondon@fk|mlaw.com); Omar Ochoa (OOchoa@susmangodfrey.com); Warren T. Burns; Frantangelo,
`Barbara K; Davis, Kenneth R.
`Subject: RE: Call regarding Delphi
`
`I think it would be helpful to go ahead with the call at 11:30 a.m. ET Wed., if possible. Would Delphi be
`available for the meeting on Jan. 29? We will be in Detroit for the Jan. 28 status conf.
`
`From: Papelian, Joseph E [mailto:joseph.e.papelian@delphi.com]
`Sent: Monday, January 12, 2015 8:47 AM
`To: Vicky Romanenko; Yeager, Judy
`Cc: Billy London (blondon@fk|mlaw.com); Omar Ochoa (OOchoa@susmangodfrey.com); Warren T. Burns; Frantangelo,
`Barbara K; Gangnes, Larry
`Subject: RE: Call regarding Delphi
`
`|t’s to review what we plan to collect and schedule a meeting with you probably sometime for the first week of
`February.
`If you prefer, let me know if you're available the first of Feb and we can schedule a date and
`dispense with the call.
`|’m including Larry on my response — thanks
`
`From: Vicky Romanenko [mai|to:Vicky@cuneo|aw.com]
`Sent: Monday, January 12, 2015 11:27 AM
`To: Papelian, Joseph E; Yeager, Judy
`
`

`
`2:12-md-02311-MOB-MKM Doc # 1276-3 Filed 03/31/16 Pg 5 of 21 Pg ID 22331
`2:12-md-02311-MOB-MKM DOC # 1276-3 Filed O3/31/16 Pg 5 Of 21
`Pg ID 22331
`
`Cc: Billy London (blondon@fk|mlaw.com); Omar Ochoa (OOchoa@susmangodfrey.com); Warren T. Burns
`Subject: Call regarding Delphi
`
`Joe and Judy,
`
`I have conferred with my co-counsel, copied here. We would like to propose 9:30 am CT/10:30 am ET, on
`Wednesday. Could you tell us a little bit more about what Delphi would like to discuss on the call?
`
`Victoria Romanenko, Esquire
`Cuneo Gilbert & LaDuca
`507 C St. NE
`
`Washington D.C.
`20002
`
`Phone: (202)449-3958
`
`The information contained in this message may be attorney-client or work-product privileged and should be
`treated as confidential information intended only for the use of the individual or entity named above. If the
`reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the
`intended recipient, you are hereby notified that any dissemination, distribution or copying of this
`communication is strictly prohibited. If you have received this communication in error, please immediately
`notify us by return e-mail, destroying the original message and any copies.
`****************************************************************************************
`
`Note: If the reader of this message is not the intended recipient, or an employee or agent responsible for
`delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or
`copying of this communication is strictly prohibited. If you have received this communication in error, please
`notify us immediately by replying to the message and deleting it from your computer. Thank you.
`****************************************************************************************
`
`~» LVATL?'&'{~«‘NfnxxfilltV.4z4(««laflL&>?flvJJUi3(
`
`»~ '~a'i/vnanyr.worse/»zz7v¢vmm<1<‘»Vé':k<¥/cfiiéu-I~Ak*%:m\’#<«<Vfi>IA‘KWW3Q1MIN?‘:5:a7€rA:*L2»&'A7J.*:~«s:<yz:(MW::¢N~‘»L\>>$1»eL<z»7<«4«L¢:»K/nzfiimrw¢:%”v¢::1t4z<¢‘:'m\4mv/$vV>iim4era
`
`«.»,»—»«m»(m.»va».\m».\«7.«»~
`
`5aazezsrwsxmawzcwixeztaewm::rr»;.~s4«.»:°ssc\v«m\e§\»:wV~7,&w:Lu;s.a\sx2ai:<ee1Mt¢:
`
`This message 1S private or privileged. If you are not the person for whom this message is intended, please delete
`it and notify me immediately, and please do not copy or send this message to anyone else.
`
`****************************************************************************************
`
`Note: If the reader of this message is not the intended recipient, or an employee or agent responsible for
`delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or
`copying of this communication is strictly prohibited. If you have received this communication in error, please
`notify us immediately by replying to the message and deleting it from your computer. Thank you.
`****************************************************************************************
`
`****************************************************************************************
`
`Note: If the reader of this message is not the intended recipient, or an employee or agent responsible for
`delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or
`copying of this communication is strictly prohibited. If you have received this communication in error, please
`notify us immediately by replying to the message and deleting it from your computer. Thank you.
`****************************************************************************************
`****************************************************************************************
`
`Note: If the reader of this message is not the intended recipient, or an employee or agent responsible for
`delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or
`copying of this communication is strictly prohibited. If you have received this communication in error, please
`notify us immediately by replying to the message and deleting it from your computer. Thank you.
`****************************************************************************************
`
`

`
`2:12-md-02311-MOB-MKM Doc # 1276-3 Filed 03/31/16 Pg 6 of 21 Pg ID 22332
`2:12-md—O2311—MOB—MKM DOC # 1276-3 Filed O3/31/16 Pg 6 Of 21
`Pg ID 22332
`
`Exhibit H
`
`

`
`2:12-md-02311-MOB-MKM Doc # 1276-3 Filed 03/31/16 Pg 7 of 21 Pg ID 22333
`2:12-md-02311-MOB-MKM DOC # 1276-3 Filed O3/31/16 Pg 7 Of 21
`Pg ID 22333
`
`Gangnes, Larry
`
`From:
`Sent:
`To:
`Cc:
`
`Subject:
`
`Larry:
`
`Papelian, Joseph E <joseph.e.papelian@delphi.com>
`Monday, February 23, 2015 12:22 PM
`Gangnes, Larry
`steven.cherry@wilmerhale.com; Laura.Taylor@aporter.com; Davis, Kenneth R.;
`Michael.Rubin@aporter.com; cyook@portenNright.com; Frantangelo, Barbara K
`RE: Delphi/Antitrust Wire Harness
`
`I recall you were taking
`At this point we do not want to release the slides Doug reviewed at our meeting.
`copious notes. We can review this request once we reach agreement on the scope of discovery.
`
`Thanks,
`
`Joe
`
`From: Gangnes, Larry [mai|to:GangnesL@LanePowell.com]
`Sent: Thursday, February 12, 2015 12:41 PM
`To: Papelian, Joseph E
`Cc: steven.cher[y@wi|merha|e.com; Taylor, Laura Cofer; Davis, Kenneth R.; Rubin, Michael A.
`(Michael.Rubin@APORTER.COM); cyook@porterwright.com
`Subject: Delphi/Antitrust Wire Harness
`
`Joe,
`
`It was very informative.
`Thank you again for hosting the meeting with Doug Gruber at Delphi last week.
`that regard, we would request a copy by email of Doug's presentation, which we will continue to treat as
`”Highly Confidential” information. We will also continue working with plaintiffs on a set of document/data
`
`In
`
`requests to Delphi.
`
`And please give our thanks to Doug for taking the time to speak with us.
`
`Regards.
`
`Larry Gangnes
`LANE POWELL
`54‘l‘T0b?,NE‘v‘S £1. CUUNEELCIHS
`
`Shareholder, By | vCard
`Lane Powell PC
`1420 Fifth Avenue, Suite 4200
`P.O. Box 91302
`Seattle, WA 98111-9402
`Direct: 206.223.7036
`Cell: 206.779.6745
`wwwianegowellcom
`
`.
`
`

`
`2:12-md-02311-MOB-MKM Doc # 1276-3 Filed 03/31/16 Pg 8 of 21 Pg ID 22334
`2:12-md—O2311—MOB—MKM DOC # 1276-3 Filed O3/31/16 Pg 8 Of 21
`Pg ID 22334
`
`,«,1./«’«.‘*.v.\~:r~'y3*/?'«rri»:»«,'v:»!‘»I:\'«*.
`
`M,»-A x K
`
`#21‘
`
`~
`
`,-
`
`’-4"\/VM-:’1.':\’J.r7t/~’Al/47:51:’:-?’K*':4»,,w«.r»\
`
`Iv;-A'»~:\.:«'1rf::r/ICJSQ-r>))’~'(€' mu»
`
`1»*‘~*.\‘~k1¢‘rt“;\'"v’><<«%\$(~r‘N‘:4.3<¢’o:v/;6$4J5Vy4:
`
`~Je:w
`
`:;A-»:»;<\\‘.{.'r‘_"'o"4«\'Lo:u<4:.1¢"5:/st:¢WHA$7o\'<'4<4\k:m7Wo<«<r%:.\w:;:«r:>;r/CW/®:m'ct=1x53<%:¢':e&é5
`
`This message is private or privileged. If you are not the person for whom this message is intended, please delete
`it and notify me immediately, and please do not copy or send this message to anyone else.
`
`****************************************************************************************
`
`Note: If the reader of this message is not the intended recipient, or an employee or agent responsible for
`delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or
`copying of this communication is strictly prohibited. If you have received this communication in error, please
`notify us immediately by replying to the message and deleting it from your computer. Thank you.
`****************************************************************************************
`
`

`
`2:12-md-02311-MOB-MKM Doc # 1276-3 Filed 03/31/16 Pg 9 of 21 Pg ID 22335
`2:12-md—O2311—MOB—MKM DOC # 1276-3 Filed O3/31/16 Pg 9 Of 21
`Pg ID 22335
`
`Exhibit I
`
`

`
`2:12-md-02311-MOB-MKM Doc # 1276-3 Filed 03/31/16 Pg 10 of 21 Pg ID 22336
`2:12-md-02311-MOB-MKM DOC # 1276-3 Filed 03/31/16 Pg 10 Of 21
`Pg ID 22336
`
`Gangnes, Lara
`
`From:
`
`Sent:
`To:
`Cc:
`
`Subject:
`Attachments:
`
`Hi Joe,
`
`Omar Ochoa <OOchoa@susmangodfrey.com>
`
`Monday, June 22, 2015 11:22 AM
`Gangnes, Larry; Papelian, Joseph E
`Vicky Romanenko; 'b|ondon@fk|m|aw.com' (blondon@fklmlaw.com); Demetrius
`Lambrinos; Steve Williams; Davis, Kenneth R.
`RE: Auto Parts — Follow Up Discovery Requests to Delphi
`Auto Parts — Discovery Follow up Letter to De|phi.pdf
`
`I wanted to follow up on the letter sent earlier this month. ls Delphi preparing a response‘? Are there issues we
`need to discuss‘? Please let us know.
`
`Omar Ochoa | Susman Godfrey LLP
`Office: 214.754.1913 Mobile: 956.500.3362
`
`From: Gangnes, Larry [maiIto:Gangne@anePowe|l.com]
`Sent: Monday, June 08, 2015 12:44 PM
`To: Omar Ochoa; Papelian, Joseph E
`Cc: Vicky Romanenko; 'blondon@fklm|aw.com' (b|ondon@fk|m|aw.com); Demetrius Lambrinos; Steve Williams; Davis,
`Kenneth R.
`
`Subject: RE: Auto Parts — Follow Up Discovery Requests to Delphi
`
`Omar &Joe,
`
`This is to advise you that the Defendants in the Wire Harness class actions have no discovery requests to
`Delphi to add to plaintiffs’ requests. We understand that Fuji|<ura has a few limited requests it will be raising
`with Delphi in connection with the separate action filed by Ford.
`
`Regards.
`
`Larry Gangnes | Lane Powell PC
`Shareholder | B_io | vCard
`1420 Fifth Avenue. Suite 4300
`PO. Box 91302 |Se21ttle_, WA 98111-9402
`Direct: 206.223.7036 I Mobile: 206.779.6745
`GangnesL@LanePowell.com l www.1anepowell.com
`
`From: Omar Ochoa [mailto:OOchoa@susmangodfrey.com]
`Sent: Monday, June 01, 2015 8:59 AM
`To: Papelian, Joseph E
`Cc: Vicky Romanenko; 'blondon@fklm|aw.com' (blondon@fklmlaw.com); Demetrius Lambrinos; Steve Williams; Gangnes,
`Larry
`Subject: Auto Parts - Follow Up Discovery Requests to Delphi
`
`Joe,
`
`

`
`2:12-md-02311-MOB-MKM Doc # 1276-3 Filed 03/31/16 Pg 11 of 21 Pg ID 22337
`2:12-md-02311-MOB-MKM DOC # 1276-3 Filed 03/31/16 Pg 11 Of 21
`Pg ID 22337
`
`Please see the attached letter following up on our discovery requests to Delphi and let me know if you have any
`questions. Thank you.
`
`Omar Ochoa | Susman Godfrey LLP
`Office: 214.754.1913 Mobile: 956.500.3362
`
`| Suite 5100 I Dallas, Texas 75202
`901 Main St.
`HOUSTON we DALLAS 0 LOS ANGELES a SEATTLE to NEW YORK
`oochoa@susmangodfrey.com 1 Biography Page
`
`fit».zmshza-y;:$m<mt:-atvanMN19;imrmw»:vu1:dS&-N2Ae«xxvw.¢l'x,-'¢mse":y:&m—:.«.»««w_wz,Q:m.umm».-mm.m<:a.mw:«<~amamww4%zmu««mammmma:«a.w>x.;mwza4«;a~;,u»gmm« a:w;amwmasm«7xv;m<_ wazauwximmwkammvwexwaxvnkwmazaxNxmnu¢mwmhw:»:a€$m7wt:¢.w»mvi4:ae5§;§,mvm»xw¢wmamKIe»k««xwnmxwuwmicwszseasx
`
`This message is private or privileged. If you are not the person for whom this message is intended, please delete
`it and notify me immediately, and please do not copy or send this message to anyone else.
`
`

`
`2:12-md-02311-MOB-MKM Doc # 1276-3 Filed 03/31/16 Pg 12 of 21 Pg ID 22338
`2:12-md-02311-MOB-MKM DOC # 1276-3 Filed 03/31/16 Pg 12 Of 21
`Pg ID 22338
`
`Susman Godfrey L.L.P.
`a registered limited liability partnership
`SUITE 5100
`901 MAIN STREET
`DALLAS, TEXAS 75202-3775
`(214) 754-1900
`FAX (214) 754-1933
`www.susmangodfrey.c0m
`
`Suite 5100
`1000 Louisiana Street
`Houston, Texas 77002-5096
`(713) 651-9366
`
`Suite 950
`1901 Avenue of the Stars
`Los Angeles, California 90067-6029
`(310) 789-3100
`
`Suite 3800
`1201 Third Avenue
`Seattle, Washington 98101-3000
`(206) 516-3880
`
`‘
`
`15th Floor
`560 Lexington Avenue
`New York, New York 10022-6828
`(212) 336-8330
`
`E-Mail OOchoa@susmangodfrey.c0m
`
`Omar Ochoa
`Direct Dial (214)754_1913
`
`June 1,2015
`
`Larry S. Gangnes
`Lane Powell PC
`
`1420 Fifth Ave, Suite 4200
`P.O. Box 91302
`
`Seattle, WA 98111-9402
`GangnesL@LanePowell.com
`
`Joseph E. Papelian
`Delphi Legal - Litigation
`5725 Delphi Drive
`Troy, MI 48098
`Joseph.E.Pape1ian@delphi.com
`
`RE:
`
`In re Automotive Parts Antitrust Litigation
`
`Dear Sirs:
`
`This is to follow up regarding the discovery requests given to Delphi on
`December 3, 2014 (the “Original Discovery Requests”). Based on discussions
`between Delphi and the Plaintiffs in the Automotive Parts Antitrust Litigation (the
`“Plaintiffs”), and the presentation provided by Delphi on February 5, 2015, the
`Plaintiffs have narrowed the discovery requests to the following:
`
`(1) Sourcing Files:
`
`0 All documents included in sourcing files that are reasonably available and
`relate to Wire Harness Products sold from January 1, 1998 through the
`present. Based on information provided by Delphi,
`the sourcing files
`should include at least:
`
`(a) Internal management review packages submitted to the Delphi
`Price Review Group (the “DPRG”)
`for approval of bids in
`
`

`
`2:12-md-02311-MOB-MKM Doc # 1276-3 Filed 03/31/16 Pg 13 of 21 Pg ID 22339
`2:12-md-02311-MOB-MKM DOC # 1276-3 Filed 03/31/16 Pg 13 Of 21
`Pg ID 22339
`
`June 1,2015
`
`Page 2
`
`response to Requests for Quotes (“RFQS”)
`Products,
`
`for Wire Harness
`
`(b) Requests for procurement from customers and quote packages sent
`to customers in response to procurement requests for Wire Harness
`Products, both for business Delphi did and did not win
`
`(c) Supplier agreements entered into for successful bids
`
`(d) Preferred supplier agreements, such as the Aligned Business
`Framework-related agreements.
`
`(e) Internal and external communications, including e-mails-
`
`(f) Financial and price ladder analyses, and
`
`(g) Documents related to APR requests and other discount requests
`
`If the above elements do not exist in sourcing files, please advise the
`parties. The parties request that these materials be produced from other
`sources to the extent they do not exist in sourcing files.
`
`Please also provide sufficient information to explain any fields used, codes
`used, methods used, or data contained in the sourcing files.
`
`(2) Transactional Data and Documents:
`
`Transactional data that are kept in your SAP database (or other electronic
`databases if not available in SAP), are reasonably available, and concern
`your sales (or purchases from a contract manufacturer or supplier) of Wire
`Harness Products from January 1, 1996 through the present. To the extent
`available, each transaction record should include:
`
`(a) product type;
`
`(b) product description, including the model, make, and model year of
`the vehic1e(s) for which the product was intended, geographic
`market for which the Vehicle was intended, and whether the
`product was an original equipment or replacement part;
`
`(C) total sales amount;
`
`(d) quantity (units) (for each part number of Wire Harness Products
`sold and for each OEM model supplied, the quantity you sold your
`customers, including, but not limited to, OEMs and Tier 1,2 and 3
`suppliers);
`
`(e) unit price (for each part number of Wire Harness Products sold and
`for each OEM model supplied, the prices you charged your customers
`(including, but not limited to, OEMS and Tier 1,2 and 3 suppliers) and
`
`

`
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`
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`the prices your customers paid for Wire Harness Products, including
`any discounts, rebates, other payments, or other incentives you
`made or provided to your customers);
`
`(f) any costs (e.g., total cost, variable cost, materials cost, fixed cost,
`semi-variable cost, marginal cost, standard cost, research and
`development costs, engineering costs, plant and equipment
`investment for any plant or equipment used to produce the product)
`to you associated with the product;
`
`(g) sales date;
`
`(h) adjustments, including but not limited to, discounts, rebates,
`credits, and debits in the manner provided whether by product or
`by total sale;
`
`(i) descriptions of such adjustments;
`
`(j) currency and exchange rate;
`
`(k) product identifier or code;
`
`(1) part number for each product;
`
`(m) monetary components of the transaction beyond unit price (i.e.,
`sales tax, shipping or delivery fees);
`
`(n) purchaser, including all Customer information, including, but not
`limited to, customer ID number, sold to name, sold-to address, and
`ship-to name and address (if not on invoice);
`
`(o) purchaser invoice-to (including bill-to and sold-to) and ship-to
`information, including all purchaser address information;
`
`(p) location(s) to which product and invoice were sent;
`
`(q) the legal entity making the sale;
`
`(r) location of sale;
`
`(s) invoice number;
`
`(t) all other information included on invoices issued during the
`relevant period;
`
`(u) all information related to any return or refund; and
`
`(v) all information related to rebates, discounts and free goods
`including information sufficient to tie them to sales transactions
`
`(x) plant and capacity utilization rates for any plant you used to
`produce Wire Harness Products
`
`

`
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`(y) quantity of each part number of Wire Harness Products you
`produced from any plant you used to product Wire Harness
`Products
`
`(z) Revenues (gross and net of any discounts and rebates) for each part
`number of Wire Harness Products you produced and for each
`customer to whom you sold Wire Harness Products
`
`(aa) Cost tables you prepared for your own use or for the use of a
`customer or potential customer
`
`(bb) Profits, losses, and margins (gross and net) for each type of Wire
`Harness Products you produced and for each customer for which you
`produced Wire Harness Products from any plant you used to produce
`Wire Harness Products;
`
`(cc) Financial records (e.g., general ledger data, balance sheets,
`income statements) relating to your Wire Harness Products business;
`
`(dd) Customer information, including, but not limited to customer
`number, products sold, quantity sold, net and gross price charged,
`sold-to name, and ship-to name and address, sales terms, ship to and
`sold to parent company, and identification of subsidiaries, affiliates,
`and joint ventures;
`
`(ee) Average cost of producing each type of Wire Harness Product for
`each customer and for each model vehicle
`
`(fl) Bids and other prices you submitted to your customers or potential
`customers (including, but not limited to, OEMS and Tier 1, 2, and 3
`suppliers) to produce and supply Wire Harness Products
`
`Please also provide sufficient explanation of any fields used, codes used,
`methods used, or data contained in the transactional data requested above,
`including but not limited to, part decoders, customer code legends, or
`supplier code legends, adjustment code legends, or description code
`legends.
`
`(3)
`
`Strategic and Business Plans
`
`Your business plans and strategic plans that are reasonably available and
`that relate to Wire Harness Products sold from January 1, 1998 through the
`present. To the extent any business or strategic plan covers other
`automotive products in addition to Wire Harness Products,
`the Wire
`
`

`
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`Harness Product information can be separated and produced on its own
`provided that
`the information is self-contained and does not require
`referencing other product information for a full understanding of the Wire
`Harness Product business or strategic plan.
`
`0
`
`Please also provide other information sufficient to explain any fields used,
`codes used, or data contained in the business or strategic plans.
`
`(4)
`
`(5)
`
`(6)
`
`Documents regarding Delphi’s pricing policies and the training and
`instruction provided to employees regarding bidding and setting prices
`submitted to OEMS and other purchasers or potential purchasers, as well
`as determining discounts and price reductions for Wire Harness Products,
`from January 1, 1998 through the present.
`
`Documents comparing Delphi to its competitors with regard to prices,
`Wire Harness Product
`features, costs, RFQ results and profits from
`
`January 1, 1998 through the present.
`
`Studies, reports, or analyses in De1phi’s possession comparing the prices
`of Wire Harness Products to the prices of vehicles from January 1, 1998
`through the present.
`
`Sincerely,
`
`Omar Ochoa
`
`

`
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`
`Exhibit J
`
`

`
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`Gangnes, Larry
`
`From:
`Sent:
`To:
`Cc:
`
`Papelian, Joseph E <joseph.e.pape|ian@de|phi.com>
`Thursday, July 30, 2015 10:53 AM
`oochoa@susmangodfrey.com
`vicky@cuneolaw.com; b|ondon@fk|m|aw.com; DLambrinos@cpmlega|.com;
`swi||iams@cpm|ega|.com; Gangnes, Larry; Frantangelo, Barbara K
`
`Subject:
`Attachments:
`
`Wire Harness Auto Parts — Response to Discovery Requests
`KE3O Examp|e.xlsx
`
`I write in response to Omar Ochoa’s letter ofJune 1, 2015, and as a follow up to the telephone conversation
`Barbara Frantangelo and I had with you on July 24,2015. As we discussed, Delphi will conduct a reasonable
`
`search for responsive documents related to wire harness sales where they would most likely be located. Our
`responses will be limited to the following OEMS: General Motors, Ford, Fiat Chrysler, Daimler, Toyota, Honda
`and Nissan. These companies represent Delphi's main customers for wire harness sales. Your requests are
`
`noted below with ur responses below each request.
`
`1. Sourcing Files:
`
`0
`
`All documents included in sourcing files that are reasonably available and related to Wire Harness
`
`Products sold from January 1, 1998 through the
`present. Based on information provided by Delphi,
`
`_
`the sourcing files should include at least:
`
`We believe the majority of the requested information would be included in the DPRG
`packages. Delphi should have comprehensive DPRG packages for 2011 — 2014, and we agreed to
`search our records for additional DPRG packages from 2000 — 2010.
`
`a)
`
`Internal management review packages submitted to the Delphi Price Review Group (the ”DPRG”)
`
`for approval of bids in response to Requests
`Products.
`
`for Quotes ("RFQs'-)
`
`for Wire Harness
`
`This information should be included in the DPRG packages.
`
`b) Requests for procurement from customers and quote packages sent to customers in response
`to procurement requests for Wire Harness Products, both for business Delphi did and did not
`win.
`
`This information should be included in the DPRG packages.
`
`c) Supplier agreements entered into for successful bids.
`
`Delphi will search for responsive Purchase Orders.
`
`d) Preferred supplier agreements,
`
`such as the Aligned Business Framework-related
`
`agreem ents.
`
`This information would be retained by Delphi's customers.
`1
`
`

`
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`e)
`
`Internal andexternalcommunications,includinge-mails.
`
`Responsive emails should be included in the DPRG packages.
`
`f)
`
`Financial and price ladderlanalyses.
`
`This information should be included in the DPRG packages.
`
`g) Documents related to APR requests and other discount request.
`
`This information should be included in the DPRG packages.
`
`0
`
`If the above elements do not exist in sourcing files, please advise the parties. The parties request
`
`that these materials be produced from other sources to the extent they do not exist in sourcing
`files.
`
`This information would be retained by Delphi's customers.
`
`0
`
`Please also provide sufficient information to explain any fields used, codes used, methods used, or
`data contained in the sourcing files
`
`2. Transactional Data and Documents:
`
`As we discussed, Delphi began using the SAP program in approximately 2006. Delphi agrees to
`provide spreadsheets containing transaction data from 2006 — 2014. Attached to this email is a
`sample "KE30” report, which contains the following fields:
`
`Customer
`
`Customer Name
`
`Ship-to
`
`Ship-to party
`Product
`
`Product Description
`
`Product Hierarchy
`
`Product Hierarchy
`Profit Ctr
`
`Plant
`
`Plant Name
`
`Sales Revenue
`
`PKG Amortized
`
`Retro-billing
`Total Net Sales
`
`Sales Quantities
`Std. Direct Labor
`
`Std.Mfg.O/H-Fixed
`
`

`
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`
`Std. Direct Material
`
`Allied Material
`
`Ext Proc/Sub-contract
`Mexico VA - 1
`
`Mexico VA - 2
`
`Cost of Sales
`
`GROSS FACTORY PROFIT
`
`MEMO Avg Sales Price
`Total Material
`
`3. Strategic and Business Plans
`
`0 Your business plans and strategic plans that are reasonably available and that relate to Wire Harness
`Products sold from January 1, 1998 through the present. To the extent any business or strategic plan
`covers other automotive products in addition to Wire Harness Products, the Wire Harness Product
`Information can be separated and produced on its own provided that the information is self-contained
`and does not require referencing other product information for a full understanding of the Wire
`
`Harness Product business or strategic plan.
`
`We believe the information contained in Delphi's 5-Year Revenue Plan, which consists of
`specific programs by customer, will sufficiently respond to this request and will produce
`same.
`
`4. Documents regarding Delphi ‘s pricing policies and the training and instruction provided to employees
`regarding bidding and setting prices submitted to OEMs and other purchasers or
`potential purchasers, as well as determining discounts and price reductions for Wire Harness
`Products, from January 1, 1998 through the present.
`
`Delphi will search for and produce responsive documents, including documents relating to
`Delphi's Delegation of Authority policy, training materials regarding antitrust, Delphi's Code
`
`of Conduct, and the DPRG process.
`
`5. Documents comparing Delphi to its compet