LegalZoom.com Inc v. Rocket Lawyer Incorporated

Filing 122

Joint STIPULATION File of LegalZoom.com, Inc.'s Motion for Rule 11 Sanctions (ECF No. 121) Under Seal filed by Plaintiff LegalZoom.com Inc. (Attachments: # 1 Proposed Order)(Heather, Fred)

1
2
3
4
5
6
7

PATRICIA L. GLASER - State Bar No. 55668
[e-mail]
FRED D. HEATHER - State Bar No. 110650
[e-mail]
GLASER WEIL FINK HOWARD
AVCHEN & SHAPIRO LLP
10250 Constellation Boulevard, 19th Floor
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
LegalZoom.com, Inc.

8

UNITED STATES DISTRICT COURT

9

CENTRAL DISTRICT OF CALIFORNIA

10

WESTERN DIVISION

11
12
13

LEGALZOOM.COM, INC., a Delaware
corporation
Plaintiff,

14
15

v.

16

ROCKET LAWYER INCORPORATED,
a Delaware corporation

Case No. 2:12-cv-09942-GAF-AGR
JOINT STIPULATION TO SEAL
LEGALZOOM.COM, INC.’S
MOTION FOR RULE 11
SANCTIONS (ECF NO. 121)

Defendant.

Judge Gary A. Feess
740
255 East Temple St.
Los Angeles, CA
90012

Action Filed:

17

Judge:
Courtroom:
Place:

November 20, 2012

18
19
20
21
22
23
24
25
26
27
28

JOINT STIPULATION TO SEAL MOTION FOR RULE 11 SANCTIONS (ECF NO. 121)
939331.2

Defendant Rocket Lawyer Incorporated (“Rocket Lawyer”) and Plaintiff

1
2

LegalZoom, Inc. (“LegalZoom”), by and through their respective counsel of record,

3

hereby agree and stipulate as follows:
1.

4

On September 26, 2014, LegalZoom filed its “LEGALZOOM.COM,

5

INC’S NOTICE OF MOTION AND MOTION FOR RULE 11 SANCTIONS;

6

MEMORANDUM OF POINTS AND AUTHORITIES” and supporting declarations

7

(ECF No. 121) (the “Motion”).
2.

8
9

The Motion contains certain documents and information that was

designated as confidential under the terms of the Court’s Protective Order for this

10

case (the “Confidential Material”), and which Confidential Material should have been

11

filed under seal pursuant to that order.
3.

12
13

LegalZoom without redaction, and without an application for filing under seal.
4.

14
15

LegalZoom maintains that the Motion was inadvertently filed by
The parties now wish to take immediate steps to protect the Confidential

Material from disclosure pursuant to the Protective Order.
BASED ON THE ABOVE, Rocket Lawyer and LegalZoom hereby stipulate

16
17

and agree, subject to Court approval, to having the entire unredacted version of the

18

Motion, including the Declaration of Barak Vaughn and attached exhibits, removed

19

from the public court file, to having these documents filed under seal, and to allow

20

LegalZoom to file an appropriately redacted version of the Motion to be placed into

21

the public court file without seeking a new hearing date.

22

IT IS SO STIPULATED:

23

Dated: September 26, 2014

24
25
26
27
28

By: /s/Hong-An Vu (with permission)
Forrest A. Hainline III (SBN 64166)
[e-mail]
Hong-An Vu (SBN 266268)
[e-mail]
GOODWIN PROCTER LLP
Three Embarcadero Center, 24th Floor
San Francisco, California 94111

JOINT STIPULATION TO SEAL MOTION FOR RULE 11 SANCTIONS (ECF NO. 121)
939331.2

Tel.: [phone]
Fax.: [phone]

1
2

Michael T. Jones (SBN 290660)
[e-mail]
GOODWIN PROCTER LLP
135 Commonwealth Drive
Menlo Park, California 94025-1105
Tel.: [phone]
Fax.: [phone]

3
4
5
6
7
8

Attorneys for Defendant
ROCKET LAWYER INCORPORATED

9
10
11

Dated: September 26, 2014

12
13
14
15
16
17
18

By: /s/ Fred D. Heather
Patricia L. Glaser
[e-mail]
Fred D. Heather
[e-mail]
GLASER WEIL FINK HOWARD
AVCHEN & SHAPIRO LLP
10250 Constellation Boulevard,
19th Floor
Los Angeles, California 90067
Tel.: [phone]
Fax.: [phone]

19

Attorneys for Plaintiff
LEGALZOOM.COM, INC.

20
21
22
23
24
25
26
27
28

JOINT STIPULATION TO SEAL MOTION FOR RULE 11 SANCTIONS (ECF NO. 121)
939331.2

1

CERTIFICATE OF SERVICE

2

STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

3

I am employed in the County of Los Angeles, State of California; I am over the
4

age of 18 and not a party to the within action; my business address is 10250
5

Constellation Boulevard, 19th Floor, Los Angeles, California 90067.
6

On September 26, 2014, I electronically filed the following document(s) using
7

the CM/ECF system.
8

JOINT STIPULATION TO SEAL LEGALZOOM.COM, INC.’S
9

MOTION FOR RULE 11 SANCTIONS (ECF NO. 121)
10

Participants in the case are registered CM/ECF users and will be served by the
11

CM/ECF system.
12

I declare that I am employed in the office of a member of the bar of this court at
13

whose direction the service was made. I declare under penalty of perjury that the
14

above is true and correct.
15

Executed on September 26, 2014 at Los Angeles, California.
16
17

/s/ Fred Heather
Fred Heather

18
19
20
21
22
23
24
25
26
27
28

CERTIFICATE OF SERVICE
939331.2