Acco Brands, Inc. v. PC Guardian Anti-Theft Products, Inc. et al

Filing 256

SEALING ORDER ORDER (PLTF) re 253 . Signed by Judge Illston on 9/18/08. (ts, COURT STAFF) (Filed on 9/23/2008)

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Case 3:04-cv-03526-SI Document 253 Filed 09/12/2008 Page 1 of 3 1 HENRY C. BUNSOW (State Bar No. 60707) K.T. CHERIAN (State Bar No. 133967) 2 BRIAN A.E. SMITH (State Bar No. 188147) ROBERT M. HARKINS, JR. (State Bar No.179525) 3 HOWREY LLP 4 525 Market Street, Suite 3600 San Francisco, California 94105 5 Telephone: (415) 848-4900 Facsimile: (415) 848-4999 6 Attorneys for Plaintiff ACCO BRANDS, INC. d/b/a 7 KENSINGTON TECHNOLOGY GROUP 8 9 10 11 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ) Case No. 04-03526 SI ) ) STIPULATION AND [PROPOSED] ) ORDER TO FILE UNDER SEAL ) EXHIBITS 12-14, 20-22 AND 28 TO THE ) DECLARATION OF BRIAN SMITH IN ) SUPPORT OF PLAINTIFF ) KENSINGTON GROUP'S MOTION ) FOR SUMMARY JUDGMENT ) ) Date: September 22, 2008 ) Time: 9:00 a.m. ) Dept. Courtroom 10, 19th Floor Judge: The Honorable Susan Illston ) ) ) ) ) ) ACCO BRANDS, INC. d/b/a KENSINGTON 12 TECHNOLOGY GROUP,, 13 14 v. Plaintiff, 15 PC GUARDIAN ANTI-THEFT PRODUCTS, INC. and FELLOWES, INC., 16 Defendant. 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiff ACCO Brands, Inc. d/b/a Kensington Technology Group ("Kensington") and Defendant PC Guardian Anti-Theft Products, Inc. and Fellowes, Inc., hereby stipulate that Plaintiff Kensington Group's Exhibits 12-14, 20-22 and 28 to the Declaration of Brian Smith in support of Kensington Group's Motion For Summary Judgment and Exhibits 12-14, 20-22 and 28 should be filed under seal. Case No. 04-03526 SI STIPULATION AND [PROPOSED] ORDER TO FO FILE UNDER SEAL DM_US:21471413_1 Case 3:04-cv-03526-SI Document 253 Filed 09/12/2008 Page 2 of 3 1 Exhibit 12 contains excerpts from the deposition of Ann Laurenson from May 7, 2008 2 defendants have designated this transcript as "Highly Confidential ­ Attorneys' Eyes Only" under the 3 4 5 6 7 8 have designated this transcript as "Highly Confidential ­ Attorneys' Eyes Only" under the Stipulated Protective Order in this action. Exhibit 14 contains excerpts from the deposition of Steven L. Carson from April 11, 2008 Stipulated Protective Order in this action. Exhibit 13 contains excerpts from the deposition of Noah Groth from May 8, 2008 defendants 9 defendants have designated this transcript as "Highly Confidential ­ Attorneys' Eyes Only" under the 10 Stipulated Protective Order in this action. 11 12 defendants have designated this transcript as "Highly Confidential ­ Attorneys' Eyes Only" under the 13 14 15 Stipulated Protective Order in this action. Exhibit 21 contains excerpts from the deposition of Richard Harris from May 9, 2008 Exhibit 20 contains excerpts from the deposition of Ann Laurenson from February 5, 2008 16 defendants have designated this transcript as "Highly Confidential ­ Attorneys' Eyes Only" under the 17 Stipulated Protective Order in this action. 18 19 20 Stipulated Protective Order in this action 21 22 Exhibit 28 contains excerpts from the deposition of Gregorio Reyes from April 10, 2002 Exhibit 22 contains excerpts from the deposition of Gregg Reyes from May 14, 2008 defendants have designated this transcript as "Highly Confidential ­ Attorneys' Eyes Only" under the 23 defendants have designated this transcript as "Highly Confidential ­ Attorneys' Eyes Only" under the 24 Stipulated Protective Order in this action 25 26 27 28 -2- Plaintiff, Kensington Groups Renewed Motion for Summary Judgment relies on and cites the deposition testimony contained in and Exhibits 12-14, 20-22 and 28 to the Declaration of Brian Smith and therefore should be filed under seal for the same reasons. STIPULATION AND [PROPOSED] ORDER TO FILE UNDER SEAL Case No. 04-03526 SI DM_US:21471413_1 Case 3:04-cv-03526-SI Document 253 Filed 09/12/2008 Page 3 of 3 1 Dated: September 12, 2008 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 -3- HOWREY LLP By: /s/ Brian A.E. Smith Brian A.E. Smith Attorneys for Plaintiff ACCO BRANDS, INC. d/b/a KENSINGTON TECHNOLOGY GROUP Dated: September 12, 2008 KOLISCH HARTWELL, P.C. By: /s/ Thomas J. Romano Thomas J. Romano Attorneys for Defendants PC GUARDIAN ANTI-THEFT PRODUCTS, INC. and FELLOWES, INC. IT IS SO ORDERED. Dated: ___________________ Hon. Susan Illston Judge, United States District Court STIPULATION AND [PROPOSED] ORDER TO FILE UNDER SEAL Case No. 04-03526 SI DM_US:21471413_1

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