Free Motion for Reconsideration - District Court of Delaware - Delaware

Case 1 :04-cv-01258-SLR Document 334 Filed 04/17/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
MCKESSON INFORMATION SOLUTIONS LLC, )
)
Plaintiff} )
)
v. ) Civil Action No. 04-1258-SLR
)
THE TRIZETTO GROUP, INC., )
)
Defendant. )
)
MCKESSON’S MOTION FOR RECONSIDERATION OF THE
COURT’S APRIL 13, 2006 ORDER RELATING TO THE DEPOSITION
OF MARCIA J. RADOSEVICH OR, IN THE ALTERNATIVE, TO STRIKE
SELECTED PORTIONS OF THE DEPOSITION CONDUCTED BY TRIZETTO
Pursuant to Rule 37 ofthe Federal Rules of Civil Procedure and the Local
Rules of this Court, Plaintiff McKesson Information Solutions LLC (“McKesson"), by its
counsel, hereby respectfully moves this Court for reconsideration of its April 13, 2006
Order (D.I. 329) striking in its entirety McKesson’s April 10, 2006 examination of
Marcia J. Radosevich as well as imposing additional sanctions; or, in the alternative, to
strike selected portions of Ms. Radosevich’s deposition conducted by TriZetto. A
Memorandum In Support and proposed form of order are submitted herewith.
By: /s/ Michael A. Barlow
Thomas J. Allingham II (#0476)
Michael A. Barlow (#3928)
SKADDEN, ARPS, SLATE,
MEAGHER & From LLP
One Rodney Square
P.O. Box 636
Wilmington, Delaware 19899
(302) 651~3000
Attorneys for Plaintiff McKesson
Information Solutions LLC

Case 1:04-cv—01258-SLR Document 334 Filed 04/17/2006 Page 2 of 3
OF COUNSEL:
J eftley G. Randall
David W. Hansen
SKADDEN, ARPS, SLATE,
MEAGHER & FLOM LLP
525 University Avenue, Suite 1100
Palo Alto, California 94301
(650) 470-4500
DATED: April 17, 2006

Case 1:04-cv—01258-SLR Document 334 Filed 04/17/2006 Page 3 of 3
RULE 7.1.1 CERTIFICATE
I hereby certify that the subject of the foregoing motion has been discussed with
counsel for the defendant and that we have not been able to reach agreement
/s/ Michael A. Barlow
Michael A. Barlow (#3928)