Response | Filed: October 08, 2026
| Entered: October 08, 2026
Lewis v. Hirschbach Motor Lines, Inc. et al
Motor Vehicle | Illinois Southern
Sealed Response to Motion
SEALED RESPONSE to Motion re 374 MOTION for Summary Judgment Third-Party Defendant Navistar, Inc., n/k/a International Motors, LLC's Motion for Summary Judgment Against Defendant/Third-Party Plaintiff Hirschbach Motor Lines, Inc. filed by Hirschbach Motor Lines, Inc.. (Attachments: # 1 Affidavit Declaration of Nicholas Wooten for Response to Emergency Motion to Seal, # 2 Appendix App. Vol. I- Appendix of Public Materials Filed Pursuant to ECF 449, # 3 Appendix App. Vol. II-Appendix of Materials Bendix Claims Confidential, # 4 Exhibit Ex. 7-Exhibit 11 at the deposition of Daniel Haefs, the September 2015 ACC/CMS System Performance Evaluation, bearing production numbers NAV00005318 through NAV00005334., # 5 Exhibit Ex. 8- Exhibit 16 at the deposition of Daniel Haefs, comprising the Pyxis concern record 366951 and Internationals July 2015 Fusion presentation, bearing production numbers NAV00005337 through NAV00005371., # 6 Exhibit Ex. 9- Exhibit 61 at the deposition of Daniel Haefs, the electronic mail transmittal from Doug Sharp of Bendix to Brian Kohlwes and Michael Drapeau of Hirschbach dated January 26, 2018, with the Bendix marketing materials it forwarded, bearing production numbers HML020808 through HML020825., # 7 Exhibit Ex. 10 - Bendix Exhibit 100 at the deposition of James Barber, bearing production numbers BCVS 05758 through BCVS 05797, # 8 Exhibit Ex. 11 - true and correct copy of the Notices of Potential Claim served on December 18 and December 30, 2020., # 9 Exhibit Ex. 12 - Exhibit 47 at the deposition of Daniel Haefs and as Exhibit 128 at the deposition of Nicholas Broyles, Bendix technical report TR006755, bearing production numbers NAV00005372 through NAV00005378., # 10 Exhibit Ex. 16 - Exhibit 147 at the deposition of Jeff Carbaugh, Bendix document TR007504, Revision 0, FLR21 PTC 1.56, FLC20 PTC 1.38 AEBS Functional Test Validation, authored by J. Carbaugh on September 29, 2015 and reviewed by A. Kennedy on September 30, 2015, bearing production numbers BCVS 001597 through BCVS 001604, # 11 Exhibit Ex. 17- true and correct copy of the draft Settlement Agreement and Mutual Release circulated in the negotiation of the MaxxForce settlement, bearing Latham & Watkins document-management number 119754663., # 12 Exhibit Ex. 18- true and correct copy of the complaint filed in the Iowa Action, Hirschbach Motor Lines, Inc. v. Navistar, Inc., No. 2:20-cv-01031-MAR (N.D. Iowa), Document 4., # 13 Exhibit Ex. 20- Bendix Exhibit 102, and as Exhibit 4 at the deposition of Justin Miller, bearing production numbers BCVS 05455 through BCVS 05456., # 14 Exhibit Ex. 21- Bendix Exhibit 108, and as Exhibit 13 at the deposition of Justin Miller, bearing production numbers BCVS 05954 through BCVS 05955., # 2075 additional result(s)