`Case 1:24-cv-00053-TSK Document17-3 Filed 06/12/24 Page 1of2 PagelD #: 2676
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`EXHIBIT 1
`EXHIBIT 1
`
`
`
`Case 1:24-cv-00053-TSK Document 17-3 Filed 06/12/24 Page 2 of 2 PageID #: 2677
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`From:
`To:
`
`Cc:
`
`Subject:
`Date:
`Attachments:
`
`Brett A. Postal
`Patel, Priyata; Mike Cottler; Shaun Van Horn; laurafairneny@quinnemanuel.com; John R. Labbe; Neil B.
`McLaughlin; "Argall, Arthur"; M710 Team; Jamie.Obrien@Steptoe-Johnson.com; Gordon.Copland@Steptoe-
`Johnson.com; DG-Aflibercept; WFG-aflibercept@willkie.com; mhissam@hfdrlaw.com; Carl Shaffer; Andrew
`Robey; Max Gottlieb; QE - Samsung Bioepis; skl@schraderlaw.com; clt@simmermanlaw.com;
`fes@simmermanlaw.com; trey@simmermanlaw.com; SERVICE - Formycon Team; MGB-Amgen-ABP938; ABP938
`REGENERONPATENT@lists.kellogghansen.com; drpogue@cdkrlaw.com; sruby@cdkrlaw.com; Ashley Hardesty
`Odell; Kaitlyn McKitrick; Eylea Biosimilars; Eylea@wc.com
`RE: In re aflibercept - May 10 submission m/c
`Tuesday, May 21, 2024 8:16:43 AM
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`Draft Joint Proposed Order re Redacted Versions of Sealed Filings and Confidential Discovery Materials.docx
`
`Counsel,
`
`During the scheduling conference on Friday, the Court recognized “frustration with access to
`documents” and acknowledged a need for a procedure for providing the parties access to redacted
`versions of documents in all cases consolidated in this MDL proceeding.
`
`To that end, we have prepared a proposal that details a procedure for the filing of redacted versions
`of documents on the public record, and the exchange of litigation documents amongst the parties,
`including documents served on the parties but not filed with the Court. A copy of the proposal is
`attached to this email.
`
`We believe that it is in the best interest of all the parties and the public to reach an agreement on
`these access issues. We welcome any comments or proposed revisions from the parties by May 28,
`2024. To the extent that the parties are unable to reach an agreement by that date, Amgen intends to
`move the Court for an order addressing the issues raised in the attached proposal.
`
`Best regards,
`Brett
`
`
`
`Brett A. Postal
`901 New York Avenue, NW
`Suite 900 East
`Washington, D.C. 20001
`
`Main Number: 202.783.6040
`Fax Number: 202.783.6031
`Email: bpostal@rothwellfigg.com
`Website: www.rothwellfigg.com
`
`The information contained in this electronic message and any attachments to this message are intended for the exclusive use of the
`addressee(s) and may contain confidential and/or privileged information. If you are not the addressee, note that any disclosure, copy,
`distribution or use of the contents of this message is prohibited. If you are not the intended recipient, please notify Rothwell, Figg, Ernst &
`Manbeck, P.C. immediately at (202) 783-6040 or email us at bpostal@rfem.com, and destroy all copies of this message and any
`attachments.
`
`
`
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