`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
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`)
`)
`)
`)
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`
`DECLARATION OF TARA L. KURTIS IN SUPPORT OF FRESENIUS KABI’S
`MOTION FOR PARTIAL SUMMARY JUDGMENT ON PRIOR SALE
`
`I, Tara L. Kurtis, so hereby declare as follows:
`
`
`
`C.A. Nos. 1:16-cv-00651
` 1:17-cv-07903
`
`Hon. Rebecca R. Pallmeyer
`
`
`
`Plaintiff,
`
`Defendant.
`
`HOSPIRA, INC.
`
`
`
`
`
`FRESENIUS KABI USA, LLC
`
`
`
`
`
`v.
`
`
`
`
`
`
`
`
`
`
`
`
`
`1.
`
`I am an attorney with the firm of Schiff Hardin LLP, counsel for Defendant
`
`Fresenius Kabi USA, LLC in the above action. I make this Declaration in support of Fresenius
`
`Kabi’s MOTION FOR PARTIAL SUMMARY JUDGMENT ON PRIOR SALE.
`
`2.
`
`Attached as Exhibit A is a true and correct copy of a document marked with bates
`
`numbers HOSPIRA_00308480-541, 00308723–26, and 00308751-56.
`
`3.
`
`Attached as Exhibit B is a true and correct copy of a document marked with bates
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`numbers HOSPIRA_00312433-434.
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`4.
`
`Attached as Exhibit C is a true and correct copy of a document marked with bates
`
`numbers HOSPIRA_02501571-705.
`
`5.
`
`Attached as Exhibit D is a true and correct copy of a document marked with bates
`
`number HOSPIRA_02013595.
`
`6.
`
`Attached as Exhibit E is a true and correct copy of a document marked with bates
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`numbers FK-DEXMED 0196073-0196074.
`
`
`
`
`
`
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`Case: 1:16-cv-00651 Document #: 106-28 Filed: 05/08/18 Page 2 of 4 PageID #:3311
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`7.
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`Attached as Exhibit F is a true and correct copy of a document marked with bates
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`numbers HOSPIRA_00307943-946.
`
`8.
`
`Attached as Exhibit G is a true and correct copy of a document marked with bates
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`numbers HOSPIRA_00307529-530.
`
`9.
`
`Attached as Exhibit H is a true and correct copy of a document marked with bates
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`numbers HOSPIRA_00316414-422.
`
`10.
`
`Attached as Exhibit I is a true and correct copy of a portion of a document titled
`
`Hospira’s Final Response to Amended Invalidity Contentions.
`
`11.
`
`Attached as Exhibit J is a true and correct copy of a document marked with bates
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`number HOSPIRA_02013594.
`
`12.
`
`Attached as Exhibit K is a true and correct copy of a document marked with bates
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`numbers HOSPIRA_00903128-132.
`
`13.
`
`Attached as Exhibit L is a true and correct copy of a document marked with bates
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`numbers HOSPIRA_00518710-729 and 00518803.
`
`14.
`
`Attached as Exhibit M is a true and correct copy of a document marked with bates
`
`numbers HOSPIRA_00511078-079.
`
`15.
`
`Attached as Exhibit N is a true and correct copy of a document marked with bates
`
`number HOSPIRA_02013590.
`
`16.
`
`Attached as Exhibit O is a true and correct copy of a document marked with bates
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`numbers FK-DEXMED0196871-872.
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`17.
`
`Attached as Exhibit P is a true and correct copy of a document marked with bates
`
`numbers FK-DEXMED0196688-693.
`
`
`
`2
`
`
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`Case: 1:16-cv-00651 Document #: 106-28 Filed: 05/08/18 Page 3 of 4 PageID #:3312
`
`18.
`
`Attached as Exhibit Q is a true and correct copy of a document marked with bates
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`numbers HOSPIRA_02501827-837.
`
`19.
`
`Attached as Exhibit R is a true and correct copy of a document marked with bates
`
`numbers HOSPIRA_02501093-144, 167-74, and 555-56.
`
`20.
`
`Attached as Exhibit S is a true and correct copy of a document marked with bates
`
`numbers FK-DEXMED0196391-96 and 0196424-25.
`
`21.
`
`Attached as Exhibit T is a true and correct copy of a document marked with bates
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`numbers HOSPIRA_02501064-092.
`
`22.
`
`Attached as Exhibit U is a true and correct copy of a document marked with bates
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`numbers FK-DEXMED0196497-526.
`
`23.
`
`Attached as Exhibit V is a true and correct copy of a document marked with bates
`
`numbers HOSPIRA_01768591-600.
`
`24.
`
`Attached as Exhibit W is a true and correct copy of a document marked with bates
`
`numbers HOSPIRA_00356709-712.
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`25.
`
`Attached as Exhibit X is a true and correct copy of a document marked with bates
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`numbers HOSPIRA_00356713-721.
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`26.
`
`Attached as Exhibit Y is a true and correct copy of a document titled Hospira’s
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`Responses to Defendant Fresenius Kabi’s Thirs Set of Interrogatories (Nos. 14-16).
`
`27.
`
`Attached as Exhibit Z is a true and correct copy of a document marked with bates
`
`numbers FK-DEXMED0197105-120.
`
`28.
`
`Attached as Exhibit AA is a true and correct copy of a document marked with bates
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`numbers HOSPIRA_02501708-805.
`
`
`
`
`
`3
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`
`
`Case: 1:16-cv-00651 Document #: 106-28 Filed: 05/08/18 Page 4 of 4 PageID #:3313
`
`I declare under penalty of perjury under the laws of the United States of America that the
`
`foregoing is true and correct.
`
`Executed on May 8, 2018 in Chicago, IL.
`
`
`
`
`
`/s/ Tara Kurtis
`Tara Kurtis
`
`
`
`4
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`
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