13 A Yes.
14 Q Do you see the note in the middle that says,
15 "Note JD is sending a series of texts for follow-up"?
16 A Yes.
17 Q Do you know who JD is?
18 A I think that's Mr. Oder.
19 Q And do you know what "follow-up" means in this
20 context?
21 A Follow-up with Mr. Isaacman.
22 Q How do you know that?
23 A Because I talked to Mr. Oder about it.
24 Q Okay. So turning to Exhibit -- I'm sorry. Let
25 me ask you this, Ms. Sullivan.

15 that were described in his -- in your conversations
16 regarding his direct discussions with Mr. Isaacman?
17 A He had sent some texts to Mr. Isaacman, yes.
18 Q So you're referring back to Exhibit C-4, where
19 Mr. Isaacman is saying, "We need your help," and Dave
20 says, "How can I help?" and Jared says, "Paws on the
21 Street"? That one?
22 A Yes.
23 Q Okay. Any others?
24 A He may have -- I'm not sure if he forwarded me
25 the text. He may have mentioned it on the phone or

1 Dave told me that they were not going to be allowed to
2 use it, but Card Connect could continue to use it.
3 Q Okay. And then on March 4 at 9:34 a.m.,
4 Mr. Isaacman writes, "What a joke. The name Shift4 for
5 their new POS gateway." Do you see that?
6 A Yes.
7 Q Then at 10:25 a.m., Mr. Oder replies, "Wow.
8 Seriously." Do you see that?
9 A Yes.
10 Q And then at 10:34:12 a.m., Mr. Oder writes to
11 Mr. Isaacman, "As they say in the Wolf of Wall Street,
12 'F-them.'" Do you see that?
13 A Yes.
14 Q And then did you have a conversation with
15 Mr. Oder, after he sent that text message to Mr.
16 Isaacman, about that text message?
17 A I don't recall one, no.
18 Q Okay. At 10:37:55 a.m., Mr. Isaacman asks,
19 "What happened with the 'let's talk after the new year?'
20 Did I get stood up?" Do you see that?
21 A Yes.
22 Q So let's walk through some of these words from
23 Mr. Isaacman.
24 First, "What a joke, the name Shift4 for
25 their new POS gateway."

15 and Mr. Oder, and I don't know what the topic of
16 conversation was. I think he was talking about -- he
17 might have been talking about this. I don't know.
18 MR. MAITRA: Okay. That's all I have.
19 Thank you very much.
20 VIDEOGRAPHER: This concludes the
21 videotaping.
22 [Conclusion of deposition.]

1 Q All right. And then on March 4th at 9:34 a.m.,
2 Mr. Isaacman writes, "What a joke. The name Shift4 for
3 their POS gateway."
4 Do you see that?
5 A Yes.
6 Q And you were copied on that e-mail?
7 A Yes.
8 Q And then at 10:25 a.m. -- I'm sorry -- and then
9 at 10:24 a.m. you reply, "Wow. Seriously?"
10 Do you see that?
11 A Yes.
12 Q And then another minute, about a minute later,
13 at 10:25:19, you write, "As they said in the Wolf of Wall
14 Street, 'F-them.'"
15 Do you see that?
16 A Yes.
17 Q And this is you writing this to Jared?
18 A Yes.
19 Q The CEO of the defendant in this case?
20 A Yes.
21 Q And you're cc'ing your subordinate, Angela
22 Sullivan; right?
23 A Yes.
24 Q And then at 10:37 a.m., Mr. Isaacman asks, "What
25 happened with the 'let's talk after the new year?'

16 Q And then you forwarded that e-mail at --
17 consistent with your practice throughout your career, you
18 have your text messages sent to your e-mail account;
19 right?
20 A Yes.
21 Q And the reason you do that is because you can
22 search it and archive it and it can be saved like any
23 other business record; right?
24 A Correct.
25 Q All right. And so you're forwarding this

From: J. David Oder
Sent: Friday, March 4, 2016 10:25:19 AM (UTC-05:00) Eastern Time (US &
Canada)
To: Jared Isaacman
Cc: Angela Suliivan
As they say in the Wolf of Wall street F- them

From: J. David Oder
Sent: Friday, March 4, 2016 10:24:17 AM (UTC-05:00) Eastern Time (US &
Canada)
To: Jared Isaacman
Cc: Angela Sullivan
Wow. Seriously?