`
`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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`Civil Action Nos. 1:16-cv-00651
` 1:17-cv-07903
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`Hon. Judge Rebecca R. Pallmeyer
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`HOSPIRA’S MOTION TO SEAL EXHIBITS TO MOTION IN LIMINE
`TO EXCLUDE DR. ERIC SHEININ TESTIMONY
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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 exhibits to its Motion In Limine to Exclude
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`Dr. Eric Sheinin Testimony, which is filed contemporaneously herewith.
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`• Exhibits A: Rebuttal Report of Eric Sheinin, dated May 21, 2018; and
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`• Exhibits B: Deposition Transcript of Eric Sheinin, dated June 15, 2018 with
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`highlighted designations.
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`The exhibits contain confidential information including expert reports and deposition
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`transcripts discussing such confidential materials.
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`Hospira will provide the materials sought to be sealed to the Court for in camera review.
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`Hospira has also provided the materials to Fresenius Kabi.
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`Case: 1:16-cv-00651 Document #: 124 Filed: 07/15/18 Page 2 of 3 PageID #:4966
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`Dated: July 15, 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 #: 124 Filed: 07/15/18 Page 3 of 3 PageID #:4967
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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 July 15,
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`2018, the foregoing Hospira’s Motion to Seal Exhibits to Motion To Exclude Dr. Eric Sheinin’s
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`Testimony was 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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