IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

LORI RAVENSCROFT GEARE and 

ROBERT J. CASEY, II, Derivatively for the 

Benefit of HOSPIRA, INC.,

Plaintiffs,

v.

CHRISTOPHER B. BEGLEY, F. MICHAEL 

BALL, THOMAS E. WERNER, IRVING W. 

BAILEY, II, JACQUE J. SOKOLOV, 

BARBARA L. BOWLES, ROGER W. HALE, 

JOHN C. STALEY, CONNIE R. CURRAN, 

HEINO VON PRONDZYNSKI, MARK F. 

WHEELER, TERRENCE C. KEARNEY, 

RONALD A. MATRICARIA, and BRIAN J. 

SMITH,

Defendants,

–and–

HOSPIRA, INC., a Delaware corporation,

Nominal Defendant.

Case No. 11-cv-09074 (JJT)

PLAINTIFFS' NOTICE OF NON-OBJECTION IN SUPPORT OF

UNCONTESTED MOTION FOR FINAL APPROVAL OF SETTLEMENT, 

AWARD OF ATTORNEYS' FEES AND EXPENSES, AND INCENTIVE AWARDS
- 1 -

Plaintiffs Lori Ravenscroft Geare and Robert J. Casey, II ("Illinois Plaintiffs") 

respectfully submit this notice of non-objection in further support of their Uncontested Motion 

for Final Approval of Settlement, Award of Attorneys' Fees and Expenses, and Incentive Awards

of the derivative claims brought on behalf of Hospira, Inc. ("Hospira").1 Notice to Hospira

shareholders was disseminated pursuant to the Court's November 14, 2014 order granting 

preliminary approval of the Settlement and approving the Notice and Summary Notice of 

Pendency of Shareholder Derivative Actions (the "Notices") (Dkt. No. 79). See Declaration of 

Ruth Venning (Jan. 7, 2015) (Dkt. No. 84); Declaration of Willem F. Jonckheer Regarding 

Posting of Notice of Pendency and Proposed Settlement of Shareholder Derivative Actions and 

Stipulation of Settlement (Jan. 9, 2015) (Dkt. No. 85); Declaration of Katherine B. Scheele 

Regarding Posting of Notice of Pendency and Proposed Settlement of Shareholder Derivative 

Actions and Stipulation of Settlement (Jan. 9, 2015) (Dkt. No. 86).

The Notices advised Hospira shareholders of the proposed Settlement and its material 

terms, including the negotiated attorneys' fees and expenses in the amount of $2.3 million to 

Illinois Plaintiffs' Counsel and $330,000 to Delaware Plaintiff's Counsel (the "Fee and Expense 

Amount"), and the Incentive Award Amount of $3,000 for each of the Plaintiffs, to be paid from 

the Fee and Expense Amount. The Notices further advised Hospira shareholders of the January 

9, 2015 deadline for filing objections to the proposed Settlement, including the Fee and Expense 

Amount. The January 9, 2015 deadline has now passed and not a single Hospira stockholder has 

objected to the proposed Settlement.

A factor courts in the Seventh Circuit use in the approval or rejection of a settlement in 

representative litigation is an evaluation of the amount of opposition to the proposed settlement. 

 

1 All capitalized terms not defined herein shall have the same meanings and/or definitions as set 

forth in the Stipulation of Settlement dated November 3, 2014 (Dkt. No. 74).
- 2 -

Isby v. Bayh, 75 F.3d 1191, 1199 (7th Cir. 1996); Retsky Family Ltd. Partnership v. Price 

Waterhouse LLP, No. 97 C 7694, 2001 WL 1568856, *3 (N.D. Ill. Dec. 10, 2001). The lack of 

objection from Hospira shareholders further supports the reasonableness of the Settlement, 

including the Fee and Expense Amount. Retsky, 2001 WL 1568856 at *3 ("[T]he absence of 

objection to the [class action] settlement is evidence that the settlement is fair, reasonable and 

adequate."); see also, Susquehanna Corp. v. Korholz, 84 F.R.D. 316, 320-21 (N.D. Ill. 1979) 

(noting in a settlement of consolidated shareholder derivative actions, when, among other things, 

the "number of objectors, or the interest they represent, is not large, it may properly be presumed 

that the agreement is fair and adequate").

Based on the foregoing and the entire record herein, Illinois Plaintiffs respectfully request

that the Court approve the Settlement as fair, reasonable, and adequate and in the best interest of 

Hospira and Hospira shareholders, and approve the Incentive Award Amount and agreed-to Fee 

and Expense Amount.

Dated: January 16, 2015 ROBBINS ARROYO LLP

By: /s/ George C. Aguilar

George C. Aguilar

Brian J. Robbins

Ashley R. Palmer

600 B Street, Suite 1900

San Diego, CA 92101

Telephone: (619) 525-3990

Facsimile: (619) 525-3991

gaguilar@robbinsarroyo.com

brobbins@robbinsarroyo.com

apalmer@robbinsaarroyo.com

THE PASKOWITZ LAW FIRM, P.C.

Laurence D. Paskowitz 

208 East 51st Street, Suite 380

New York, New York 10022

Telephone: (212) 685-0969
- 3 -

Facsimile: (212) 685-2306

lpaskowitz@pasklaw.com

Co-Lead Counsel for Plaintiffs

–and–

LASKY & RIFKIND, LTD.

Norman Rifkind

Amelia S. Newton

351 West Hubbard Street, Suite 401

Chicago, IL 60654

Telephone: (312) 634-0057

Facsimile: (312) 634-0059

rifkind@laskyrifkind.com

newton@laskyrifkind.com

THE LAW OFFICES OF EDWARD T. 

 JOYCE & ASSOCIATES, P.C.

Edward T. Joyce

Rowena T. Parma

135 South LaSalle Street

Suite 2200

Chicago, IL 60603

Telephone: (312) 641-2600

Facsimile: (312) 641-0360

rparma@joycelaw.com

Co-Liaison Counsel for Plaintiffs

Additional Counsel:

THE GRANT LAW FIRM, PLLC

Lynda Grant

521 Fifth Avenue, 17th Floor

New York, NY 10175

Telephone: (212) 292-4441

Facsimile: (212) 292-4442 

lgrant@grantfirm.com

ROY JACOBS & ASSOCIATES

Roy L. Jacobs 

60 East 42nd Street

46th Floor 

New York, New York 10165

Telephone: (212) 867-1156

Facsimile: (212) 504-8343
- 4 -

jacobs@jacobsclasslaw.com

Additional Counsel for Plaintiff Lori 

Ravenscroft Geare

LAW OFFICE OF ALFRED 

 G. YATES, JR., P.C.

Alfred G. Yates, Jr.

519 Allegheny Building

429 Forbes Avenue

Pittsburgh, PA 15219

Telephone: (412) 391-5164

Facsimile: (412) 471-1033

yateslaw@aol.com

Additional Counsel for Plaintiff Robert J. 

Casey

1005763
CERTIFICATE OF SERVICE

I hereby certify that on January 16, 2015, I electronically filed the foregoing with the 

Clerk of the Court using the CM/ECF system, which will send notification of such filing to the email addresses denoted on the Electronic Mail Notice List.

/s/ George C. Aguilar

GEORGE C. AGUILAR

ROBBINS ARROYO LLP

600 B Street, Suite 1900

San Diego, CA 92101

Telephone: (619) 525-3990

Facsimile: (619) 525-3991

gaguilar@robbinsarroyo.com