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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
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`v.
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`Plaintiff,
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`Defendant.
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`HOSPIRA, INC.
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`FRESENIUS KABI USA, LLC
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`C.A. Nos. 16-cv-0651
` 17-cv-7903
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`Hon. Judge Rebecca R. Pallmeyer
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`HOSPIRA’S MOTION TO SEAL EXHIBITS TO MOTIONS IN LIMINE BRIEFING
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`Pursuant to Local Rule 26.2, Plaintiff Hospira, Inc. (“Hospira”) respectfully requests that
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`the Court grant leave to file under seal the following portions of the parties’ [Proposed] Joint
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`Pre-Trial Order, which is filed contemporaneously herewith.
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`• Exhibits A-P to Fresenius Kabi’s Motions In Limine; and
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`• Exhibits A-C to Hospira’s Response to Fresenius Kabi’s Motions In Limine.
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`A listing of each Exhibit is provided in Pre-Trial Order Exhibits VI-A-2 and VI-B-2. The
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`materials contain confidential information produced during the litigation (confidential regulatory
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`submission, license and supply agreement, and expert reports / deposition transcripts discussing
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`such confidential materials). The information was provided subject to the Stipulated Protective
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`Order entered by the Court. (D.I. 25.)
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`Hospira will provide the materials sought to be sealed to the Court as part of the courtesy
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`copy of the Proposed Joint Pre-Trial Order. Hospira has also provided the materials to Fresenius
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`Kabi.
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`Fresenius Kabi does not oppose Hospira’s request to seal these materials.
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`Case: 1:16-cv-00651 Document #: 116 Filed: 06/25/18 Page 2 of 3 PageID #:4833
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`Dated: June 25, 2018
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`Respectfully submitted,
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`By: /s/ Bradford P. Lyerla
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`Bradford P. Lyerla
`Sara T. Horton
`Aaron A. Barlow
`Yusuf Esat
`Ren-How Harn
`JENNER & BLOCK LLP
`353 N. Clark Street
`Chicago, IL 60654-3456
`(312) 222-9350
`blyerla@jenner.com
`shorton@jenner.com
`abarlow@jenner.com
`yesat@jenner.com
`rharn@jenner.com
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`Attorneys for Plaintiff
`Hospira, Inc.
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`2
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`Case: 1:16-cv-00651 Document #: 116 Filed: 06/25/18 Page 3 of 3 PageID #:4834
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`CERTIFICATE OF SERVICE
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`I, Yusuf Esat, an attorney at the law firm of Jenner & Block LLP, certify that on June 25,
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`2018, the foregoing Hospira’s Motion to Seal Exhibits to Motions In Limine Briefing was
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`electronically served on counsel of record via the Court’s CM/ECF system.
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`/s/ Yusuf Esat
`Yusuf Esat
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