`
`John T. Bennett
`
`617.570.8712
`jbennett@goodwinprocter.com
`
`Goodwin Procter LLP
`
`Counselors at Law
`Exchange Place
`Boston, MA 02109
`T: 617.570.1000
`F: 617.523.1231
`
`March 7, 2016
`
`David L. Anstaett. Esq.
`Perkins Coie LLP
`
`One East Main Street
`
`Suite 201
`
`Madison. WI 53703-51 18
`
`Re:
`
`
`
`In re C0 axone 40 m Consolidated Cases C.A. No. 14-cv—1l71 . Del.
`
`Dear David:
`
`I write in response to your January February 26, 2016 letter concerning several discovery issues.
`
`
`
`Second. we confmn that Plaintiffs have marked the deposition transcripts of Dr. Jerry Wolinsky
`and Irit Pinchasi as outside cormsel eyes only 11nder the protective order because their testimony
`pertained to confidential proprietary research and development activity conducted by Teva. These
`designations have been nrade in accordance with Paragraph 9(c) of the Stipulated Protective Order,
`which explicitly permits the designation of whole deposition transcripts. These designations are also
`consistent with the practice of all the parties to this litigation. who have marked deposition transcripts
`containing confidential or proprietary information as outside counsel eyes only or highly confidential
`under the protective order in their entirety. We see no reason to depart from this practice. To the extent
`all of the defendants believe that a different approach is necessary. we are willing to participate in a
`meet and confer discussion among all of the parties on this issue. We do not agree that Teva’s
`designations under the protective order are improper.
`
`
`
`MYLAN PHARMS. INC. EXHIBIT 1144 PAGE 1
`
`
`
`David L. Anstaett, Esq.
`March 7, 2016
`
`Page 2
`
`
`
`Sincerely,
`
`/s/ John T. Bennett
`
`John T. Bennett
`
`MYLAN PHARMS. INC. EXHIBIT 1144 PAGE 2