LegalZoom.com Inc v. Rocket Lawyer Incorporated
Filing
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APPLICATION for Order for Granting Leave to File Documents Under Seal filed by plaintiff LegalZoom.com, Inc. Plaintiff LegalZoom.com, Inc. will and hereby does apply for an order permitting them to file under seal the following: 1) Unredacted Notice of Motion and Motion of LegalZoom.com, Inc. to Supplement Factual Record in Opposition to Defendant Rocket Lawyer Incorporateds Motion for Summary Judgment; (2) Unredacted Declaration of Barak Vaugh in Support of LegalZoom.com, Inc.s Motion to Supplement Factual Record; and (3) Exhibits to Declaration of Barak Vaughn filed by Plaintiff LegalZoom.com Inc. (Attachments: # 1 Proposed Order)(Heather, Fred)
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PATRICIA L. GLASER - State Bar No. 55668
pglaser@glaserweil.com
FRED D. HEATHER - State Bar No. 110650
fheather@glaserweil.com
GLASER WEIL FINK
HOWARD AVCHEN & SHAPIRO LLP
10250 Constellation Boulevard, 19th Floor
Los Angeles, California 90067
Telephone: (310) 553-3000
Facsimile: (310) 556-2920
Attorneys for Plaintiff
LegalZoom.com, Inc.
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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WESTERN DIVISION
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LEGALZOOM.COM, INC., a Delaware
corporation,
Plaintiff,
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v.
ROCKET LAWYER INCORPORATED,
a Delaware corporation,
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Defendants.
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CASE NO.: CV 12-9942-GAF (AGRx)
PLAINTIFF LEGALZOOM.COM,
INC.’S APPLICATION FOR AN
ORDER GRANTING LEAVE TO
FILE DOCUMENTS UNDER SEAL
Date:
Time:
Judge:
Courtroom:
Action Filed:
TBD
TBD
Hon. Gary A. Feess
740
November 20, 2012
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LEGALZOOM’S APPLICATION FOR AN ORDER GRANTING LEAVE TO FILE DOCUMENTS UNDER SEAL
898075.1
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TO ALL PARTIES AND THEIR ATTORENYS OF RECORDS HEREIN:
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NOTICE IS HEREBY GIVEN that in accordance with Local Rule 79-5.1, of
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the Central District of California, Plaintiff LegalZoom.com, Inc. (“LegalZoom”)
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hereby applies for an order permitting them to file under seal the following:
1) Unredacted Notice of Motion and Motion of LegalZoom.com, Inc. to
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Supplement Factual Record in Opposition to Defendant Rocket Lawyer Incoporated’s
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Motion for Summary Judgment.
2) Unredacted Declaration of Barak Vaughn Barak Vaugh in Support of the
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Motion of LegalZoom.com, Inc. to Supplement Factual Record in Opposition to
Defendant Rocket Lawyer Incoporated’s Motion for Summary Judgment.
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3) Exhibits to Declaration of Barak Vaughn.
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This application is made pursuant to Local Rule 79-5 et seq. and the Stipulated
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Protective Order, entered on September 24, 2013 (ECF No. 39).
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REASONS SUPPORTING RELIEF REQUESTED
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Good cause exists to seal the Reply Memorandum of Points and Authorities
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and Evidentiary Objections. These documents are subject to the Court’s protective
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order and the sealing of these documents is necessary in order to protect information
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that Rocket Lawyer has designated as “confidential” or “attorneys’ eyes only,”
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including without limitation, confidential business information and other sensitive
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business data relating to Rocket Lawyer Incorporated. See Protective Order, ECF No.
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39, at 5-7.
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LEGALZOOM’S APPLICATION FOR AN ORDER GRANTING LEAVE TO FILE DOCUMENTS UNDER SEAL
898075.1
CONCLUSION
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For the foregoing reasons, LegalZoom.com, Inc. respectfully requests that the
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Court order its Notice of Motion and Motion of LegalZoom.com Inc. to Supplement
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Factual Record in Opposition to Defendant Rocket Lawyer Incorporated’s Motion for
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Summary Judgment, the Declaration of Barak Vaughn filed under seal.
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DATED: September 29, 2014
Respectfully submitted,
GLASER WEIL FINK JACOBS
HOWARD AVCHEN & SHAPIRO LLP
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By:
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/s/ Fred Heather
PATRICIA L. GLASER
FRED D. HEATHER
PATRICIA J. WINOGRAD
Attorneys for Plaintiff
LegalZoom.com, Inc.
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LEGALZOOM’S APPLICATION FOR AN ORDER GRANTING LEAVE TO FILE DOCUMENTS UNDER SEAL
898075.1
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