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`Exhibit A
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`Case: 1:16-cv-00651 Document #: 99-1 Filed: 05/03/18 Page 2 of 4 PageID #:2580
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
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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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`FRESENIUS KABI USA, LLC
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`v.
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`[PROPOSED] JOINT STIPULATION
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`This stipulation is made by and between Plaintiff Hospira, Inc. (“Hospira”) and
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`Defendant Fresenius Kabi USA, LLC (“Fresenius Kabi”) (collectively, “the Parties”).
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`WHEREAS the Court entered a Stipulated Protective Order in the above-referenced
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`matter on March 21, 2016 (D.I. 25, 1:16-cv-00651);
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`WHEREAS the Parties modified the Stipulated Protective Order on February 8, 2018
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`(D.I. 94, 1:16-cv-00651), which the Court entered on February 12, 2018 (D.I. 96, 1:16-cv-
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`00651), which is currently in effect;
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`WHEREAS the Stipulated Protective Order allows for the filing under seal and redaction
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`of confidential information (D.I. 25, 1:16-cv-00651 at ¶¶ 12-13), including information initially
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`disclosed without a confidentiality marking (Id. at ¶ 16);
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`WHEREAS the Stipulated Protective Order defines “Confidential Information” to
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`include non-public business plans and competitively sensitive business information (Id. at
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`¶ 2(d)(i));
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`3
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`Case: 1:16-cv-00651 Document #: 99-1 Filed: 05/03/18 Page 3 of 4 PageID #:2581
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`WHEREAS the Court issued a Transcript of Proceedings held on January 25, 2018 (“the
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`Transcript”) (D.I. 91, 1:16-cv-00651; D.I. 34, 1:17-cv-07903), which included a discussion of
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`the date before which Fresenius Kabi would not launch its product;
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`WHEREAS the Court entered a Stipulation on January 29, 2018, which included a date
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`for the event titled “Fresenius Kabi Will Not Launch (Without Opinion) Before” (D.I. 89, 93,
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`1:16-cv-00651; D.I. 32, 36, 1:17-cv-07903);
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`WHEREAS the date before which Fresenius Kabi would not launch its product is
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`Confidential Information under the terms of the Stipulated Protective Order (D.I. 25, 1:16-cv-
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`00651, at ¶ 2(d)(i));
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`WHEREAS Fresenius Kabi now wishes to seal the Stipulation and refile a public version
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`redacting the date corresponding to the event titled “Fresenius Kabi Will Not Launch (Without
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`Opinion) Before;”
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`WHEREAS Fresenius Kabi now wishes to seal the Transcript;
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`It is hereby STIPULATED AND AGREED, subject to the approval of the Court, that:
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`1.
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`Fresenius Kabi is granted leave to file the Stipulation under seal and refile a
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`public version redacting the date associated with the event titled “Fresenius Kabi Will Not
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`Launch (Without Opinion) Before.”
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`2.
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`Fresenius Kabi is granted leave to seal portions of the Transcript related to the
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`date before which Fresenius Kabi would not launch its product, and refile a public version
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`redacting the date before which Fresenius Kabi would not launch its product without an opinion.
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`2
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`Case: 1:16-cv-00651 Document #: 99-1 Filed: 05/03/18 Page 4 of 4 PageID #:2582
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`Date:
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`ENTERED:
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`REBECCA R. PALLMEYER
`United States District Judge
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`3
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