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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
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`Case No. 16-cv-8637
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`Judge Thomas M. Durkin
`Magistrate Judge Jeffrey T. Gilbert
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`____________________________________
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`IN RE:
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`BROILER CHICKEN ANTITRUST )
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`LITIGATION
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`This Document Relates to All Actions
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`UNITED STATES’ MOTION FOR LIMITED DEPOSITION STAY
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`Intervenor United States respectfully files this motion for a limited deposition
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`stay. If permitted to proceed now, these depositions would interfere with the United
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`States’ upcoming trial, pending litigation, and ongoing grand-jury investigation. As
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`explained in the accompanying brief that the United States is submitting to the Court ex
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`parte because it contains grand-jury information, see Fed.R.Crim.P. 6(e), the Court
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`should grant this motion.1
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`1 The United States is not filing a notice of presentment and not providing courtesy copies of this motion
`because the Court has suspended the operation of those rules. See Eighth Amended General Order 20-
`0012 at ¶¶ 5-6 (Nov. 13, 2020).
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`Case: 1:16-cv-08637 Document #: 4516 Filed: 04/05/21 Page 2 of 3 PageID #:297960
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`Dated: April 5, 2021
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`Respectfully submitted,
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`_____________________________
`PAUL J. TORZILLI, Trial Attorney
`MICHAEL T. KOENIG, Trial Attorney
`HEATHER CALL, Trial Attorney
`CAROLYN M. SWEENEY, Trial Attorney
`U.S. Department of Justice
`Antitrust Division
`450 5th St NW
`Washington, DC 20530
`202/514.8349
`Paul.Torzilli@usdoj.gov
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`Case: 1:16-cv-08637 Document #: 4516 Filed: 04/05/21 Page 3 of 3 PageID #:297961
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`CERTIFICATE OF SERVICE
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`I hereby certify that I have caused the foregoing to be filed on the Court’s
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`CM/ECF system, which automatically provides notice to counsel for all parties to the
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`above-captioned action.
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`Dated: April 5, 2021
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`Respectfully submitted,
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`Paul J. Torzilli
`Trial Attorney
`U.S. Department of Justice
`Antitrust Division
`450 5th St NW
`Washington, DC 20530
`202/514.8349
`Paul.Torzilli@usdoj.gov
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`3
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