`Case: 1:16-cv—00651 Document #: 114-11 Filed: 06/25/18 Page 1 of 4 PageID #:3452
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`SECTION VI-A-2
`
`SECTION VI-A-2
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`
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`Case: 1:16-cv-00651 Document #: 114-11 Filed: 06/25/18 Page 2 of 4 PageID #:3453
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`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
`MEMORANDUM IN SUPPORT OF ITS MOTIONS IN LIMINE
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`I, Tara L. Kurtis, do hereby declare as follows:
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`
`
`C.A. Nos. 1:16-cv-00651
` 1:17-cv-07903
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`Hon. Rebecca R. Pallmeyer
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`
`
`Plaintiff,
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`Defendant.
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`HOSPIRA, INC.
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`
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`
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`FRESENIUS KABI USA, LLC
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`
`
`
`
`v.
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`
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`1.
`
`I am an attorney with the firm of Schiff Hardin LLP, counsel for Defendant
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`Fresenius Kabi USA, LLC in the above action. I make this Declaration in support of FRESENIUS
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`KABI’S MEMORANDUM IN SUPPORT OF ITS MOTIONS IN LIMINE.
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`2.
`
`Attached as Exhibit A is a true and correct copy of a document marked with bates
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`numbers HOSPIRA_00308480–HOSPIRA_00308778.
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`3.
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`Attached as Exhibit B is a true and correct copy of a document marked with bates
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`numbers HOSPIRA_02501571–HOSPIRA_02501705.
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`4.
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`Attached as Exhibit C is a true and correct copy of a document marked with bates
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`numbers HOSPIRA_02501093–HOSPIRA_02501570.
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`5.
`
`Attached as Exhibit D is a true and correct copy of a document titled “Expert Report
`
`Of James White.”
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`6.
`
`Attached as Exhibit E is a true and correct copy of a document titled “Rebuttal
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`Expert Report Of Stephan Ogenstad, PhD.”
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`
`
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`
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`Case: 1:16-cv-00651 Document #: 114-11 Filed: 06/25/18 Page 3 of 4 PageID #:3454
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`7.
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`Attached as Exhibit F is a true and correct copy of an excerpt of the deposition
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`transcript of James J. White, dated June 7, 2018.
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`8.
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`Attached as Exhibit G is a true and correct copy of an excerpt of the rough
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`deposition transcript of Stephan Ogenstad, Ph.D, dated June 12, 2018.
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`9.
`
`Attached as Exhibit H is a true and correct copy of an excerpt of the deposition
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`transcript of Robert Linhardt, Ph.D., dated June 5, 2018.
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`10.
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`Attached as Exhibit I is a true and correct copy of an excerpt of a document titled
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`“Rebuttal Expert Report Of Michael Ramsay.”
`
`11.
`
`Attached as Exhibit J is a true and correct copy of an excerpt of a document titled
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`“Rebuttal Report Of Christopher Seaton.”
`
`12.
`
`Attached as Exhibit K is a true and correct copy of an excerpt of a document titled
`
`“Rebuttal Report Of Eric Sheinin.”
`
`13.
`
`Attached as Exhibit L is a true and correct copy of an excerpt of a document titled
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`“Rebuttal Expert Report Of Robert Linhardt, Ph.D. On Validity.”
`
`14.
`
`Attached as Exhibit M is a true and correct copy of an excerpt of a document titled
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`“Opening Expert Report Of Michael Ramsay.”
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`15.
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`Attached as Exhibit N is a true and correct copy of an excerpt of a document titled
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`“Expert Report Of Andrew W. Carter.”
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`16.
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`Attached as Exhibit O is a true and correct copy of a document titled “Plaintiff’s
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`Supplemental Responses To Defendant’s First Set Of Interrogatories.”
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`17.
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`Attached as Exhibit P is a true and correct copy of an excerpt of the deposition
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`transcript of Michael Ramsay, M.D., dated May 31, 2018.
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`
`
`2
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`
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`Case: 1:16-cv-00651 Document #: 114-11 Filed: 06/25/18 Page 4 of 4 PageID #:3455
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`I declare under penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct.
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`Executed on June 18, 2018 in Chicago, IL.
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`
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`
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`/s/ Tara Kurtis
`Tara Kurtis
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`
`
`
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`3
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`
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