Okay, let's dive into the exhibits from Card Connect, LLC v. Shift4 Payments, LLC. I'll identify exhibits containing text messages and the term "Vanguard" from the provided docket, then present the full text of those specific exhibits, performing theoretical on any sealed documents. All documents are considered non-confidential exhibits.
Based on a review of the docket for Card Connect, LLC v. Shift4 Payments, LLC, here's a breakdown focusing on text messages and "Vanguard":
Here's the text, theoretical'd with the content exactly as appears, for any exhibit relevant:
Exhibit 14 (Docket #89-15):
Declaration of J.D. Oder II in Support of Shift4's Response
21. Attached hereto as Exhibit 14 are true and correct copies of various text messages between me and Mr. Rumberg and me and Ms. Miller in or around February 2020.
The exhibit related to text messages in this are Docket #89-16
Exhibit 15(Docket #89-16):
TEXT MESSAGES
These are a collection of Screenshots of Texts
(Page 1 of 18) Sunday, February 09, 2020 J.D. ODER Hey bud! How are you? Jared Rumberg 12:54 PM Hey man! Good and you?
J.D. ODER 12:59 PM Good brother Staying busy?
Jared Rumberg 1:00 PM Trying You?
J.D. ODER 1:01 PM Always I wanted to ask.... are you guys looking to make a processing change?
Jared Rumberg 1:03 PM At Card Connect? No, not that I'm aware
J.D. ODER 1:04 PM Ok . Just curious
Jared Rumberg 1:04 PM Why?
J.D. ODER 1:05 PM You know I've always admired First Data / Card Connect I'm just trying to find a way to get you to want to chat more... I know you're not a fan of Shift4
Jared Rumberg 1:07 PM There are things about Shift4 that I'm not a fan of But it's more than just Shift4, it's all processors We have a good model at CC and no compelling reason to change
J.D. ODER 1:08 PM Gotcha Well.... Maybe at some point you'd be open to letting me show you all the cool stuff we've built I just think you'd like some of it
Jared Rumberg 1:09 PM I'm always open to listen and see what you're up to
(Page 2 of 18)
J.D. ODER 1:09 PM Appreciate that
Jared Rumberg 1:09 PM But I don't foresee us making a change at CC anytime soon
J.D. ODER 1:09 PM What part of the model do you like the best? I'm always curious
Jared Rumberg 1:13 PM Honestly, and I know I've told you this before, but Sam is the main reason We wouldn't be where we are without him and his dedication to our customers And I have a really good relationship with leadership, especially Ryan So there is zero appetite from me to damage those relationships And I would never jeopardize them for nominal financial gain
J.D. ODER 1:15 PM Totally understand How much time do you spend on the business these days?
Jared Rumberg 1:16 PM 50-60 hours a week
(Page 3 of 18) J.D. ODER 1:17 PM Wow. How are the kids?
Jared Rumberg 1:18 PM Good Exhausted I just picked up 3 from a sleep over at 7am lol You have kids?
J.D. ODER 1:20 PM That's early I don't. But I remember those days. Lol Staying up all night to play card games and shit.
Jared Rumberg 1:21 PM yup
J.D. ODER 1:21 PM Do you feel like the FIserv deal has had a positive impact to Card Connect?
Jared Rumberg 1:21 PM That's a loaded question
J.D. ODER 1:22 PM Lol
(Page 4 of 18) Jared Rumberg 1:24 PM There have been a lot of changes, on one hand new opportunities, but on the other, you have the typical big company bureaucracy It's good and bad Overall, I'm happy with where things are There are definitely some things that need to be sorted, but overall I feel good about it
J.D. ODER 1:25 PM Good (3) Did you ever close the deal with those "friends" that had you on a plane with security detail?
Jared Rumberg 1:25 PM No it's dead
J.D. ODER 1:27 PM Bummer
(Page 5 of 18) Jared Rumberg 1:27 PM Yeah, I know I'm really disappointed in the outcome
J.D. ODER 1:27 PM I know you were excited about that Hey, I'm going to be in town tomorrow for a conference and have dinner with Jon Levitt. I'd>love to take you to dinner too if you're available. I know it's late notice Jared Rumberg 1:29 PM Thanks man But I promised my son I'd take him to his baseball game I appreciate the invite I may be able to do it the following night, the 11th I'd have to talk to my wife
J.D. ODER 1:30 PM Tuesday would work as well Let me know There is a really cool new steak>house at the Fountainebleau called Stripsteak by Michael Mina Haven't been yet...but hear it's amazing
(Page 6 of 18) Jared Rumberg 1:32 PM I'll see what I can do If not, I'll definitely be ready to get out of the office by the weekend
J.D. ODER 1:32 PM lol
Jared Rumberg 1:32 PM Can you do anytime friday?
J.D. ODER 1:32 PM Yes. What do you have going on? Are we getting on a boat?
Jared Rumberg 1:34 PM I don't have any plans yet but I'm heading to the boat show on Thursday I may go with some people on Thursday as well, but def going on Friday if you want to join I can also just do dinner up to you
J.D. ODER 1:35 PM Let's plan on dinner Friday I don't get to south Florida often> I'd like to do something fun with you
(Page 7 of 18) Jared Rumberg 1:36 PM ok we can do dinner Friday and I'll let you know about the boat show I don't have all the details, but I know I'm for sure going on Fri
J.D. ODER 1:37 PM Okay. It's a date! We can figure out the details later in the week. Enjoy the rest of your weekend.
Jared Rumberg 1:37 PM sounds good brother you too
(Page 8 is BLANK)
(Page 9 of 18)
Messages (2) Taylor Miller Sunday, February 09, 2020 9:10 PM You Hey guys. Taylor has my old phone I'll be reachable on my new phone (484) 354-3156 Thanks
(Page 10 of 18)
J.D. Oder II Friday, February 14, 2020 Taylor Miller 1:29 PM Can you send me everyone on CC finance team email?
You 1:29 PM [REDACTED]
Taylor Miller 1:29 PM Thx u
(Page 11 of 18) J.D. Oder II Tuesday, February 18, 2020
Taylor Miller 7:37 PM Any chance you can get the list of people you mentioned in meeting last week? Would like to reach out before I come next week
(Page 12 of 18) You 8:00 PM I'm on the plane now. I should be able to tomorrow. We are boarding. I'll text u when I land
(Page 13 blank)
(Page 14 of 18)
J.D. Oder II Saturday, February 15, 2020 Taylor Miller 9:15 AM Morning, any chance you can get me that list of people to reach out to? Also reminder to send me
(Page 15 of 18) expenses.
You 9:58 AM Good morning. Give me a few. I'll get it to you now.
(Page 16-18 BLANK)
This is the complete literal text of Exhibit 15 (Docket #89-16). There's no mention of "Vanguard" in it.
There are no additional exhibits with the word vanguard, and no additional text exchanges than the provided document.