Oracle Corporation et al v. SAP AG et al

Filing 576

Declaration of Bree Hann in Support of 575 Administrative Motion to Seal filed byOracle EMEA Limited, Oracle International Corporation, Oracle USA Inc., Siebel Systems, Inc.. (Russell, Chad) (Filed on 12/11/2009) Modified on 12/14/2009 (vlk, COURT STAFF).

Oracle Corporation et al v. SAP AG et al

Doc. 576

Case4:07-cv-01658-PJH Document576

Filed12/11/09 Page1 of 2

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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 OAKLAND DIVISION ORACLE USA, INC., et al., v. Plaintiffs, CASE NO. 07-CV-01658 PJH (EDL) DECLARATION OF BREE HANN IN SUPPORT OF PLAINTIFFS' ADMINISTRATIVE MOTION TO PERMIT PLAINTIFFS TO FILE UNDER SEAL DEFENDANTS' INFORMATION SUPPORTING PLAINTIFFS' MOTION TO MODIFY THE PROTECTIVE ORDER AND TO COMPEL DEPOSITION TESTIMONY AND FURTHER RESPONSES TO REQUESTS FOR ADMISSIONS

SAP AG, et al., Defendants.

Case No. 07-CV-01658 PJH (EDL)
DECLARATION OF BREE HANN 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 Document576

Filed12/11/09 Page2 of 2

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I, Bree Hann, declare: 1. I am an attorney at law licensed to practice in the State of California and

before this Court, and am counsel at Bingham McCutchen LLP, counsel of record for plaintiffs Oracle USA, Inc., Oracle International Corporation, Oracle EMEA Limited, and Siebel Systems, Inc. (together, "Oracle") in this action. I have personal knowledge of the facts stated below by virtue of my representation of Oracle in this action, and, if called as a witness, could competently testify as to them. 2. Pursuant to Civil Local Rule 79-5 and the stipulated Protective Order entered

on June 6, 2007 in this case, I make this Declaration in support of Plaintiffs' Administrative Motion to Permit Plaintiffs to File Under Seal Defendants' Information Supporting Plaintiffs' Motion to Modify the Protective Order and to Compel Deposition Testimony and Further Responses to Requests for Admissions ("Motion to Compel"). 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 until such time as Defendants may submit a declaration in accordance with Civil Local Rule 79-5(d), and the Court makes a final ruling as to confidentiality of the relevant subject matter. 4. Specifically, Exhibit T to the Declaration of Chad Russell in Support of

Plaintiffs' Motion to Compel, lodged with the Court on December 11, 2009, contains information designated by Defendants under the Protective Order in this action. 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 December 11, 2009, in San Francisco, California. /s/ Bree Hann______ Bree Hann

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Case No. 07-CV-01658 PJH (EDL)

DECLARATION OF BREE HANN IN SUPPORT OF PLAINTIFFS' ADMINISTRATIVE MOTION TO PERMIT PLAINTIFFS TO FILE UNDER SEAL DEFENDANTS' INFORMATION SUPPORTING PLAINTIFFS' MOTION TO COMPEL