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Case Law Update: 7th Circuit Discovery

Gotham Holdings, LP v. Health Grades, Inc., No. 09-2377 affirmed that the district court did not err in enforcing subpoena requiring defendant to turn over certain documents relating to arbitration award even though defendant argued that it could not do so due to existence of confidentiality agreement it had with third-party to keep information contained in said documents secret. Plaintiff was entitled to view relevant evidence as part of discovery in instant case with defendant, and defendant’s pledge for secrecy did not create legal bar to disclosure in instant case as long as said disclosure was compelled via subpoena. This seventh circuit case will have an impact on Illinois federal cases.