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

Filing 293

SEALING ORDER re 292 . Signed by Judge Illston on 10/29/08. (ts, COURT STAFF) (Filed on 10/29/2008)

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Case 3:04-cv-03526-SI Document 292 Filed 10/28/2008 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 ) CORRECTED 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: October 28, 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 On September 12, 2008, Plaintiff ACCO Brands, Inc. d/b/a Kensington Technology Group ("Kensington") and Defendant PC Guardian Anti-Theft Products, Inc. and Fellowes, Inc., stipulated to file Kensington's Exhibits 12-14, 20-22 and 28 to the Declaration of Brian Smith in support of Kensington Group's Motion For Summary Judgment under seal [Dkt. No. 253], and the Court issued an order granting that motion on September 23, 2008 [Dkt. No. 256]. However, the exhibits filed on that date did not include all the agreed-upon and cited pages, so Kensington hereby submits the same stipulation, that Kensington and defendants stipulate that Kensington's Exhibits 12-14, 20-22 and 28 to Case No. 04-03526 SI STIPULATION AND [PROPOSED] ORDER TO FO FILE UNDER SEAL DM_US:21560729_1 Case 3:04-cv-03526-SI Document 292 Filed 10/28/2008 Page 2 of 3 1 the Declaration of Brian Smith in support of Kensington Group's Motion For Summary Judgment and 2 Exhibits 12-14, 20-22 and 28 should be filed under seal. Those corrected exhibits include the 3 following: 4 Corrected Exhibit 12 contains excerpts from the deposition of Ann Laurenson from May 7, 5 2008 defendants have designated this transcript as "Highly Confidential Attorneys' Eyes Only" 6 7 8 9 10 11 defendants have designated this transcript as "Highly Confidential Attorneys' Eyes Only" under the Stipulated Protective Order in this action. Corrected Exhibit 14 contains excerpts from the deposition of Steven L. Carson from April 11, under the Stipulated Protective Order in this action. Corrected Exhibit 13 contains excerpts from the deposition of Noah Groth from May 8, 2008 12 2008 defendants have designated this transcript as "Highly Confidential Attorneys' Eyes Only" 13 under the Stipulated Protective Order in this action. 14 15 2008 defendants have designated this transcript as "Highly Confidential Attorneys' Eyes Only" 16 17 18 under the Stipulated Protective Order in this action. Corrected Exhibit 21 contains excerpts from the deposition of Richard Harris from May 9, Corrected Exhibit 20 contains excerpts from the deposition of Ann Laurenson from February 5, 19 2008 defendants have designated this transcript as "Highly Confidential Attorneys' Eyes Only" 20 under the Stipulated Protective Order in this action. 21 22 23 Stipulated Protective Order in this action. 24 25 Corrected Exhibit 28 contains excerpts from the deposition of Gregorio Reyes from April 10, Corrected 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 26 2002 defendants have designated this transcript as "Highly Confidential Attorneys' Eyes Only" 27 under the Stipulated Protective Order in this action. 28 -2- STIPULATION AND [PROPOSED] ORDER TO FILE UNDER SEAL Case No. 04-03526 SI DM_US:21560729_1 Case 3:04-cv-03526-SI Document 292 Filed 10/28/2008 Page 3 of 3 1 Kensington's September 12, 2008 Motion for Summary Judgment relies on and cites the 2 deposition testimony contained in and Corrected Exhibits 12-14, 20-22 and 28 to the Declaration of 3 4 5 6 7 8 9 10 11 12 Dated: October 28, 2008 13 14 15 16 17 18 19 IT IS SO ORDERED. 20 21 Dated: ___________________ 22 23 24 25 26 27 28 -3- Brian Smith and therefore should be filed under seal for the same reasons. Dated: October 28, 2008 HOWREY LLP By: /s/ Brian A.E. Smith Brian A.E. Smith Attorneys for Plaintiff ACCO BRANDS, INC. d/b/a KENSINGTON TECHNOLOGY GROUP KOLISCH HARTWELL, P.C. By: /s/ Thomas J. Romano Thomas J. Romano Attorneys for Defendants PC GUARDIAN ANTI-THEFT PRODUCTS, INC. and FELLOWES, INC. Hon. Susan Illston Judge, United States District Court STIPULATION AND [PROPOSED] ORDER TO FILE UNDER SEAL Case No. 04-03526 SI DM_US:21560729_1

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