`Case 1:17-cv-00868—CFC-SRF Document 171-1 Filed 05/20/20 Page 1 of 3 PageID #: 6837
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`EXHIBIT “A”
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`EXHIBIT “A”
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`Case 1:17-cv-00868-CFC-SRF Document 171-1 Filed 05/20/20 Page 2 of 3 PageID #: 6838
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`UNIVERSITY OF MASSACHUSETTS and
`CARMEL LABORATORIES LLC,
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` Plaintiffs,
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`v.
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`L’ORÉAL USA, INC.,
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` Defendant.
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`C.A. No. 17-868-CFC-SRF
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`[PROPOSED] ORDER
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`W H E R E A S , Defendant L’Oréal USA, Inc. (“L’Oréal USA”), having moved the Court
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`to compel Plaintiffs to supplement their responses to L’Oréal USA’s Interrogatory Nos. 1, 8, 9,
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`and 11;
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`WHEREAS, L’Oréal USA, having moved the Court to compel Plaintiffs to supplement
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`and correct their privilege log and produce any non-privileged documents;
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`WHEREAS, L’Oréal USA, having moved the Court to compel Plaintiffs to produce
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`documents relating to the Teresian Carmelites; and
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`WHEREAS, the Court having considered the Motion and any opposition thereto,
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`I T I S H E R E B Y O R D E R E D this ____ day of ________________, 2020 that the
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`Motion is G R A N T E D . Plaintiffs shall: (1) supplement their responses to L’Oréal USA’s
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`Interrogatory Nos. 1, 8, 9, and 11 to include all non-privileged factual information relating to the
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`testing underlying Plaintiffs’ infringement contentions and/or Plaintiffs’ testing referenced in the
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`2015 and 2016 correspondence between the parties; (2) supplement their privilege log with
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`descriptions that identify the specific litigation that forms the basis for Plaintiffs’ work product
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`claims and sufficient factual information for L’Oréal USA to assess Plaintiffs’ privilege
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`Case 1:17-cv-00868-CFC-SRF Document 171-1 Filed 05/20/20 Page 3 of 3 PageID #: 6839
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`assertions and/or produce any non-privileged documents; and (3) produce documents pertaining
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`to the financial condition and outlays of the Teresian Carmelites since 2008 and documents
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`pertaining to former Teresian Carmelites (and Carmel Labs) President Dennis Wyrzykowski’s
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`decision to separate from that organization.
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`___________________________________
`Hon. Sherry R. Fallon, U.S.M.J.
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