IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

SUNBEAM PRODUCTS, INC., )
a Delaware corporation, )
)No.97C6313
Plaintiff)
)Judge Leinenweber
v.)
)Magistrate Judge Keys
AMERICAN MEDICAL ASSOCIATION,)
an Illinois corporation,)
)
Defendant.)
)
ASSOCIATION OF AMERICAN)
PHYSICIANS & SURGEONS, INC.,)
)
Intervenor. )

RESPONSE OF DEFENDANT AMERICAN MEDICAL
ASSOCIATION
TO THIS COURT'S ORDER OF NOVEMBER 3, 1998

Defendant American Medical Association ("AMA"), by its attorneys, submits this status report regarding the confidentiality of documents produced in this case:

1. In an order dated November 3, 1998, this Court rescinded the Stipulated Protective Order Governing Confidentiality ("Confidentiality Order"). The Court granted the AMA leave to file a motion for a new protective order identifying any documents it wishes to keep confidential.1

2. Only one document which the AMA previously designated as "confidential" pursuant to the Confidentiality Order has been filed with the Court. Plaintiff Sunbeam Products, Inc. ("Sunbeam") filed that document under seal. Upon further review, the AMA does not assert confidentiality for that particular document.

3. As to the remaining documents that the AMA produced to Sunbeam during this lawsuit, Sunbeam and the AMA have agreed, wholly apart from the status of the Confidentiality Order, to maintain the confidentiality of each other's confidential documents. In addition, the parties intend to return copies of each other's documents to the producing party. Thus, because the rescission of the Confidentiality Order affects only one document, and because the AMA no longer asserts confidentiality for that document, the AMA does not seek the entry of a new protective order.

Respectfully submitted,

AMERICAN MEDICAL ASSOCIATION

1 Certain non-parties, e.g. Minnesota Mining and Manufacturing Co., produced documents to Sunbeam and the AMA which were designated confidential under the Confidentiality Order. The AMA assumes that the Confidentiality Order continues to apply to those documents. < p>