LegalZoom.com Inc v. Rocket Lawyer Incorporated

Filing 77

APPLICATION for Order 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 Plaintiff LegalZoom.com, Inc. s Statement of Genuine Disputes in Opposition to Rocket Lawyerss Motion for Summary Judgment and/or Adjudication; 2) Unredacted Declaration of Patricia Winograd in Support of LegalZoom.com, Inc.s Opposition to Rocket Lawyer Incorporateds Motion for Summary Judgment and/or Adjudication filed by Plaintiff LegalZoom.com Inc. (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

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

13
14
15

v.
ROCKET LAWYER INCORPORATED,
a Delaware corporation,

16

Defendants.

17

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:

August 18, 2014
9:30 a.m.
Hon. Gary A. Feess
740
November 20, 2012

[Memorandum of Points and
Authorities; Statement of Genuine
Disputes; Declaration of Patricia J.
Winograd, Declaration of Alan Goedde,
Declaration Dr. Bruce Isaacson and
Notice of Lodging]

18
19
20
21
22
23
24
25
26
27
28

LEGALZOOM’S APPLICATION FOR AN ORDER GRANTING LEAVE TO FILE DOCUMENTS UNDER SEAL
898075.1

1

TO ALL PARTIES AND THEIR ATTORENYS OF RECORDS HEREIN:

2

NOTICE IS HEREBY GIVEN that in accordance with Local Rule 79-5.1, of

3

the Central District of California, Plaintiff LegalZoom.com, Inc. (“LegalZoom”)

4

hereby applies for an order permitting them to file under seal the following:
1) Plaintiff LegalZoom.com, Inc.’s Statement of Genuine Disputes

5
6

(Unredacted) in Opposition to Rocket Lawyer Incorporated’s Motion for Summary

7

Judgment and/or Adjudication; and
2) Declaration of Patricia J. Winograd (Unredacted) in Support of

8
9
10

LegalZoom.com, Inc.’s Opposition to Rocket Lawyer Incorporated’s Motion for
Summary Judgment and/or Adjudication.

11

This application is made pursuant to Local Rule 79-5 et seq. and the Stipulated

12

Protective Order, entered on September 24, 2013 (ECF No. 39), and is based on those

13

reasons, the Statement of Genuine Disputes and the Declaration of Patricia J.

14

Winograd.
REASONS SUPPORTING RELIEF REQUESTED

15
16

Good cause exists to seal the Statement of Genuine Disputes and the

17

Declaration of Patricia J. Winograd. These documents are subject to the Court’s

18

protective order and the sealing of these documents is necessary in order to protect

19

information that Rocket Lawyer has designated as “confidential” or “attorneys’ eyes

20

only,” including without limitation, confidential business information and other

21

sensitive business data relating to Rocket Lawyer Incorporated. See Protective Order,

22

ECF No. 39, at 5-7.

23

///

24

///

25

///

26

///

27

///

28

2
LEGALZOOM’S APPLICATION FOR AN ORDER GRANTING LEAVE TO FILE DOCUMENTS UNDER SEAL
898075.1

CONCLUSION

1

For the foregoing reasons, LegalZoom.com, Inc. respectfully requests that the

2
3

Court order its Statement of Genuine Disputes and the Declaration of Patricia J.

4

Winograd be filed under seal.

5
6

DATED: July 24, 2014

Respectfully submitted,
GLASER WEIL FINK JACOBS
HOWARD AVCHEN & SHAPIRO LLP

7
8
9

By:

10
11
12
13

/s/ Fred Heather
PATRICIA L. GLASER
FRED D. HEATHER
PATRICIA J. WINOGRAD
Attorneys for Plaintiff
LegalZoom.com, Inc.

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

3
LEGALZOOM’S APPLICATION FOR AN ORDER GRANTING LEAVE TO FILE DOCUMENTS UNDER SEAL
898075.1