Oracle Corporation et al v. SAP AG et al

Filing 517

Declaration of Zachary Alinder in Support of 515 MOTION to Seal Defendants' Information Supporting Plaintiffs' Motion to Compel filed byOracle USA Inc.. (Related document(s) 515 ) (Alinder, Zachary) (Filed on 10/20/2009)

Oracle Corporation et al v. SAP AG et al

Doc. 517

Case4:07-cv-01658-PJH Document517

Filed10/20/09 Page1 of 2

1 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

BINGHAM McCUTCHEN LLP DONN P. PICKETT (SBN 72257) GEOFFREY M. HOWARD (SBN 157468) HOLLY A. HOUSE (SBN 136045) ZACHARY J. ALINDER (SBN 209009) BREE HANN (SBN 215695) Three Embarcadero Center San Francisco, CA 94111-4067 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] [e-mail] [e-mail] [e-mail] DORIAN DALEY (SBN 129049) JENNIFER GLOSS (SBN 154227) 500 Oracle Parkway, M/S 5op7 Redwood City, CA 94070 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] Attorneys for Plaintiffs Oracle USA, Inc., Oracle International Corporation, Oracle EMEA Limited, and Siebel Systems, Inc. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ORACLE USA, INC., et al., v. Plaintiffs, CASE NO. 07-CV-01658 PJH (EDL) DECLARATION OF ZACHARY ALINDER IN SUPPORT OF PLAINTIFFS' ADMINISTRATIVE MOTION TO PERMIT PLAINTIFFS TO FILE UNDER SEAL DEFENDANTS' INFORMATION SUPPORTING PLAINTIFFS' MOTION TO COMPEL PRODUCTION OF DAMAGESRELATED DOCUMENTS AND INFORMATION

SAP AG, et al., Defendants.

Case No. 07-CV-01658 PJH (EDL)
DECLARATION OF ZACHARY ALINDER IN SUPPORT OF PLAINTIFFS' ADMINISTRATIVE MOTION TO PERMIT PLAINTIFFS TO FILE UNDER SEAL DEFENDANTS' INFORMATION SUPPORTING PLAINTIFFS' MOTION TO COMPEL

Dockets.Justia.com

Case4:07-cv-01658-PJH Document517

Filed10/20/09 Page2 of 2

1 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

I, Zachary Alinder, declare: 1. I am a partner in the law firm of Bingham McCutchen LLP and counsel of

record for Plaintiffs Oracle USA, Inc., Oracle International Corporation, Oracle EMEA Limited, and Siebel Systems, Inc. (collectively "Oracle") in the above-captioned action. I am a member in good standing of the state bar of California and admitted to practice before this Court. I make this declaration based on personal knowledge and, if called upon to do so, could testify competently thereto. 2. I make this Declaration in support of Plaintiffs' Administrative Motion to

Permit Plaintiffs to File Under Seal Defendants' Information Supporting Plaintiffs' Motion to Compel Production of Damages-Related Documents and Information. 3. Plaintiffs file this motion at Defendants' request. The requested relief is

necessary and narrowly tailored to protect the alleged confidentiality of the materials put at issue by Plaintiffs' Motion to Compel Production of Damages-Related Documents and Information until such time as Defendants may submit a declaration in accordance with Civil Local Rule 795(d), and the Court makes a final ruling as to confidentiality of the relevant subject matter. Specifically, the following documents and portions of documents lodged with the Court contain information designated by Defendants as "Confidential Information" or "Highly Confidential Information ­ Attorneys' Eyes Only": (1) certain portions of Plaintiffs' Motion to Compel Production of Damages Related Documents and Information at pp. 6:28-7:1 and 12:5-12:16; (2) certain portions of the Declaration of Amy Donnelly in Support of Plaintiffs' Motion to Compel Production of Damages Related Documents and Information ("Donnelly Declaration") at ¶17; and (3) Exhibit B to the Donnelly Declaration. Plaintiffs lodged copies of this material with the Court on October 20, 2009. I declare under the laws of the United States and the State of California that the foregoing is true and correct and that this Declaration was executed on October 20, 2009, in San Francisco, California. /s/Zachary Alinder____ Zachary Alinder 2
Case No. 07-CV-01658 PJH (EDL)
DECLARATION OF ZACHARY ALINDER IN SUPPORT OF PLAINTIFFS' ADMINISTRATIVE MOTION TO PERMIT PLAINTIFFS TO FILE UNDER SEAL DEFENDANTS' INFORMATION SUPPORTING PLAINTIFFS' MOTION TO COMPEL