Document bBGaae4mXJbay53785gnjv0V0

Case: 2:13-md-02433-EAS-EPD Doc #: 2702 Filed: 03/26/15 Page: 1 of 3 PAGEID #: 39270 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION IN RE: E.I. DU PONT DE NEMOURS AND COMPANY C-8 PERSONAL INJURY LITIGATION CASE NO: 2:13-MD-2433 JUDGE EDMUND A. SARGUS, JR. MAGISTRATE JUDGE ELIZABETH P. DEAVERS This document relates to: Carla Marie Bartlett v. E.I. du Pont de Nemours and Company, Case No. 2:13-cv-160. John M. Wolf v. E.I. du Pont de Nemours and Company, Case No. 2:14-cv-095. TRIAL PLAINTIFFS' NOTICE OF FILING NON-CONFIDENTIAL VERSIONS OF EXPERT REPORTS PREVIOUSLY FILED UNDER SEAL On February 3, 2015, Plaintiffs Carla Bartlett and Jon Wolf ("Trial Plaintiffs") moved the Court for leave to file the following documents under seal as exhibits to their Opposition to Defendant's Motion to Compel Discovery Responses from Trial Plaintiffs (the "Opposition"), (ECF Nos. 2034 & 2036), on the grounds that the reports referred to information designated "confidential" under the Agreed Protective Order in this MDL, (ECF No. 27): - Exhibit H: Expert Report for Stephen E. Petty - Exhibit I: Expert Report of Steven Amter: - Exhibit J: Expert Report of James S. Smith; - Exhibit K: Expert Report of Barry S. Levy; Case: 2:13-md-02433-EAS-EPD Doc #: 2702 Filed: 03/26/15 Page: 2 of 3 PAGEID #: 39271 - Exhibit L: Expert Report of Michael B. Siegel; and - Exhibit M: Expert Report of David L. Macintosh After the Court granted the Motion For Leave on February 3, 2015, (ECF No. 2034), Trial Plaintiffs submitted to the Court, under seal, the confidential versions of the expert reports at issue (the "Expert Reports"), and referred to such filings under seal in the exhibits publicly-filed in support of their Opposition. (See ECF. Nos. 2036-9 through 2036-14). Since such time, Trial Plaintiffs have been able to create non-confidential versions of each of the Expert Reports by redacting any purportedly "confidential" information from the confidential versions already on file under seal. Thus, in an effort to minimize the extent of any information filed under seal in this matter, Trial Plaintiffs are hereby filing the redacted, non-confidential versions of the Expert Reports to be substituted for the documents currently in the public court file at ECF Nos. 2036-9 through 2036-14, with the confidential versions remaining under seal. Respectfully submitted, s/ Michael A. London_________ Michael A. London Douglas & London, P.C. 59 Maiden Lane, 6th Floor New York, NY 10038 Telephone: 212-566-7500 Fax: 212-566-7501 Email: mlondon@douglasandlondon.com 14732655.1 Jon C. Conlin Cory Watson 2131 Magnolia Ave., Suite 200 Birmingham, AL 35205 2 Case: 2:13-md-02433-EAS-EPD Doc #: 2702 Filed: 03/26/15 Page: 3 of 3 PAGEID #: 39272 Telephone: 205-328-2200 Fax: 205-324-7896 Email: conlin@cwcd.com Robert A. Bilott Taft Stettinius & Hollister LLP Cincinnati, Ohio 45202-3957 Telephone: 513-381-2838 Fax: 513-381-0205 Email: Bilott@taftlaw.com Plaintiffs' Steering Committee Co-Lead Counsel CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was electronically filed with this Court's CM/ECF on this 26th day of March 2015 and was thus served electronically upon all counsel of record. s/ Michael A. London Michael A. London 14732655.1 3