`
`Exhibit A
`
`
`
`Exhibit
`No.
`1
`
`2
`
`Case 2:22-md-03034-TGB ECF No. 138-1, PageID.10094 Filed 05/04/23 Page 2 of 3
`Exhibit A - Index of Documents Proposed for Sealing
`
`Description of Confidential Materials
`
`Designation
`
`Designating Part(ies)
`
`Letter of Request for Assistance from Spanish
`Authorities (highlighted portions).
`The highlighted portions reference a supplier
`relationship, the existence of which was disclosed
`to Neo via discovery disclosures and documents
`produced by a Defendant and designated “Highly
`Confidential – Attorney’s Eyes Only.” The
`highlighted portions also reveal the identities of
`the products supplied in the course of the same.
`Letter of Request for Assistance from Chinese
`Authorities (highlighted portions).
`The highlighted portions reference supplier
`relationships, the existence of which were
`disclosed to Neo via documents produced by a
`Defendant and a third-party supplier, and which
`were designated “Highly Confidential –
`Attorney’s Eyes Only.” The highlighted portions
`also reveal the identities of the products supplied
`in the course of the same.
`
`The highlighted portions
`reference information
`contained in materials
`designated Highly
`Confidential –
`Attorney’s Eyes Only.
`
`The Defendants
`referenced in the
`portions of the Letter
`marked for redaction.1
`
`The highlighted portions
`reference information
`contained in materials
`designated Highly
`Confidential –
`Attorney’s Eyes Only.
`
`The Defendant
`referenced in the
`portions of the Letter
`marked for redaction;
`and the third-party
`supplier, subpoenaed in
`this action, whose
`overseas affiliates are
`referenced in the
`portions of the Letter
`marked for redaction.
`
`
`1 While Neo is aware that LR 5.3(b)(3)(A)(iii) requires the party moving to file materials under seal to identify the
`party who designated the material in question as confidential, here there is a dilemma in that giving the identity of
`the relevant entities in a public filing would necessarily reveal the existence of the supplier relationships which
`Neo is seeking to protect in the first place. Neo believes that their identities are readily ascertainable from the
`descriptions provided herein.
`
`
`
`1
`
`
`
`Exhibit
`No.
`3
`
`Case 2:22-md-03034-TGB ECF No. 138-1, PageID.10095 Filed 05/04/23 Page 3 of 3
`Exhibit A - Index of Documents Proposed for Sealing
`
`Description of Confidential Materials
`
`Designation
`
`Designating Part(ies)
`
`Letter of Request for Assistance from
`Luxembourgish Authorities (highlighted portions).
`The highlighted portions reference supplier
`relationships, the existence of which were
`disclosed to Neo via documents produced by a
`third party and designated “Highly Confidential –
`Attorney’s Eyes Only.” The highlighted portions
`also reveal the identities of the products supplied
`in the course of the same.
`
`The highlighted portions
`reference information
`contained in materials
`designated Highly
`Confidential –
`Attorney’s Eyes Only.
`
`The third party whose
`identity is listed within
`the definition of
`“Suppliers” and is
`marked for redaction.
`
`
`
`
`
`2
`
`