RTC Industries, Inc. v. Fasteners for Retail, Inc.

MOTION

N.D. Ill.June 10, 2019

1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION RTC Industries, Inc., Plaintiff, v. Fasteners For Retail, Inc., Defendant. ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 1:17-cv-03595 Judge: Honorable Sharon J. Coleman Magistrate: Honorable Sidney I. Schenkier JURY TRIAL DEMANDED DEFENDANT FASTENERS FOR RETAIL, INC.’S UNOPPOSED MOTION FOR LEAVE TO FILE EXHIBITS A, B, AND C TO ITS MOTION TO COMPEL RESPONSES TO INTERROGATORY NOS. 4 AND 11 UNDER SEAL Pursuant to Local Rule 26.2, Defendant Fasteners for Retail, Inc. (“FFR”) requests leave to file an unredacted version of Exhibits A, B, and C to its Motion to Compel Responses to Interrogatory Nos. 4 and 11 (the “Confidential Documents”) under seal. In support of the Motion, FFR states: 1. The Confidential Documents have been designated by FFR and/or RTC as “Highly Confidential – Attorneys’ Eyes Only,” or refer to and discuss information designated by FFR and/or RTC as “Highly Confidential – Attorneys’ Eyes Only,” indicating that the documents contain competitively sensitive and confidential information. 2. In accordance with Local Rule 26.2, FFR will file a public redacted version of its Motion to Compel Responses to Interrogatory Nos. 4 and 11, and Exhibits A–C thereto, concurrently with the filing of this motion. WHEREFORE, FFR respectfully requests that the Court grant it leave to file the Confidential Documents under seal. Case: 1:17-cv-03595 Document #: 181 Filed: 06/10/19 Page 1 of 3 PageID #:11940 2 Meet-and-Confer Statement On June 10, 2019, counsel for FFR sent counsel for RTC an email asking whether RTC intends to oppose this motion. RTC indicated that it does not oppose the motion. Dated: June 10, 2019 Respectfully submitted, /s/ Gianni L. Cutri Gianni L. Cutri (IL Bar No. 6272109) gianni.cutri@kirkland.com Joel R. Merkin (IL Bar No. 6290212) joel.merkin@kirkland.com Brian A. Verbus (IL Bar No. 6314193) brian.verbus@kirkland.com KIRKLAND & ELLIS LLP 300 North LaSalle Chicago, Illinois 60654 Telephone: (312) 862-2000 Facsimile: (312) 862-2200 Counsel for Defendant Fasteners For Retail, Inc. Case: 1:17-cv-03595 Document #: 181 Filed: 06/10/19 Page 2 of 3 PageID #:11941 CERTIFICATE OF SERVICE The undersigned attorney hereby certifies that all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document via the Court’s CM/ECF system on June 10, 2019. /s/ Gianni L. Cutri Attorney for Fasteners for Retail, Inc. Case: 1:17-cv-03595 Document #: 181 Filed: 06/10/19 Page 3 of 3 PageID #:11942