Apple Inc. v. Psystar Corporation

Filing 58

AFFIDAVIT re 57 MOTION to Seal Document (Miscellaneous Administrative Request For An Order Permitting The Filing Under Seal Of Confidential Portions Of Letter Brief Dated April 29, 2009) MOTION to Seal Document (Miscellaneous Administrative Request For An Order Permitting The Filing Under Seal Of Confidential Portions Of Letter Brief Dated April 29, 2009) (Declaration of Megan M. Chung In Support of Administrative Request) by Apple Inc.(a California corporation). (Chung, Megan) (Filed on 4/29/2009)

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Apple Inc. v. Psystar Corporation Doc. 58 Case3:08-cv-03251-WHA Document58 Filed04/29/09 Page1 of 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TOWNSEND AND TOWNSEND AND CREW LLP JAMES G. GILLILAND, JR. (State Bar No. 107988) MEHRNAZ BOROUMAND SMITH (State Bar No. 197271) MEGAN M. CHUNG (State Bar No. 232044) J. JEB B. OBLAK (State Bar No. 241384) Two Embarcadero Center, Eighth Floor San Francisco, CA 94111 Telephone: (415) 576-0200 Facsimile: (415) 576-0300 Email: jggilliland@townsend.com mboroumand@townsend.com mmchung@townsend.com jboblak@townsend.com Attorneys for Plaintiff and Counterdefendant APPLE INC. UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION APPLE INC., a California corporation, Plaintiff, v. PSYSTAR CORPORATION, a Florida corporation, and DOES 1-10, inclusive, Defendants. AND RELATED COUNTERCLAIMS Case No. CV 08-03251 WHA DECLARATION OF MEGAN M. CHUNG IN SUPPORT OF MISCELLANEOUS ADMINISTRATIVE REQUEST FOR AN ORDER PERMITTING THE FILING UNDER SEAL OF LETTER BRIEF DATED APRIL 29, 2009 I, Megan M. Chung, declare as follows: 1. I am an attorney licensed to practice law in the State of California and am admitted to practice before this Court. I am an associate in the law firm of Townsend and Townsend and Crew LLP, and am one of the attorneys representing Plaintiff and counterdefendant Apple Inc. ("Apple") in the above captioned matter. I make this declaration on personal knowledge and if called as a witness could and would competently testify with respect to the matters stated herein. DECLARATION OF MEGAN M. CHUNG IN SUPPORT OF MISCELLANEOUS ADMINISTRATIVE REQUEST FOR AN ORDER PERMITTING THE FILING UNDER SEAL, CASE NO. CV 08-03251 WHA 1 Dockets.Justia.com Case3:08-cv-03251-WHA Document58 Filed04/29/09 Page2 of 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 61922737 v1 2. 3. On March 2, 2009, the Court entered a Stipulated Protective Order in this case. Pursuant to the Stipulated Protective Order entered in this case and Civil Local Rule 79-5(c), portions of the letter brief and entirety of Exhibits A, B and D are sealable because they contain confidential financial information of defendant and counterclaimant Psystar Corporation ("Psystar") which have been designated "CONFIDENTIAL" by Psystar. Since the confidential information has been disclosed in this case under the terms of the Stipulated Protective Order, the confidential information and documents have not been disclosed to the public and maintained in such manner to ensure that they are not disclosed to the public. 4. L.R. 79-5(c). I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct to the best of my knowledge and belief. Executed on April 29, 2009, at San Francisco, California. Apple has lodged with the Clerk a sealed copy of these documents pursuant to Civil /s/ Megan M. Chung Megan M. Chung DECLARATION OF MEGAN M. CHUNG IN SUPPORT OF MISCELLANEOUS ADMINISTRATIVE REQUEST FOR AN ORDER PERMITTING THE FILING UNDER SEAL, CASE NO. CV 08-03251 WHA 2