Apple Inc. v. Psystar Corporation

Filing 186

MOTION Motion to Seal Motion in Opposition filed by Psystar Corporation. (Attachments: # 1 Proposed Order)(Camara, Kiwi) (Filed on 10/13/2009)

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Apple Inc. v. Psystar Corporation Doc. 186 Case3:08-cv-03251-WHA Document186 Filed10/13/09 Page1 of 3 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 K.A.D. CAMARA (TX Bar No. 24062646/ MA Bar No. 661087 Admitted Pro Hac Vice) camara@camarasibley.com KENT RADFORD (TX Bar No. 24027640 Admitted Pro Hac Vice) radford@camarasibley.com CAMARA & SIBLEY LLP 2339 University Boulevard Houston, Texas 77005 Telephone: (713) 893-7973 Facsimile: (713) 583-1131 EUGENE ACTION (SBN 223023) eugeneaction@hotmail.com 1780 E. Barstow Ave., #5 Fresno, California 93710 Telephone: (559) 283-9772 Facsimile: (559) 642-2843 Attorney for Defendant/Counterclaimant PSYSTAR CORPORATION IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION APPLE INC., a California corporation, Plaintiff, v. PSYSTAR CORPORATION, Defendants. AND RELATED COUNTERCLAIMS CASE NO. CV-08-03251-WHA MISCELLANEOUS ADMINISTRATIVE MOTION TO FILE UNDER SEAL PSYSTAR CORPORATION'S OPPOSITION TO APPLE'S MOTION TO SEAL APPLE'S MOTION FOR SUMMARY JUDGMENT Defendant Psystar Corporation submits this Administrative Request pursuant to Civil Local Rules 711 and 795(d) for permission to file under seal Psystar Corporation's Opposition to Apple's Motion to Seal Apple's Motion for Summary Judgment. This motion contains information designated by Apple as Confidential or Confidential Attorneys' Eyes Only under the Stipulated Protective Order approved by this Court on March 2, 2009. Psystar itself has no interest in keeping this material under MISCELLANEOUS ADMINISTRATIVE MOTION TO FILE UNDER SEAL PSYSTAR'S OPPOSITION TO APPLE'S MOTION TO SEAL APPLE'S MOTION FOR SUMMARY JUDGMENT (CV 08-03251 WHA) 1 Dockets.Justia.com Case3:08-cv-03251-WHA Document186 Filed10/13/09 Page2 of 3 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 seal, but files this request in order to comply with the protective order. Pursuant to Civil Local Rule 795(d), a sealed copy of the above-described document is being lodged with the clerk. Dated: October 12, 2009 Respectfully submitted, CAMARA & SIBLEY LLP By: /s/ K.A.D. Camara____________________________ K.A.D. Camara Attorney for Defendant / Counterclaimant Psystar Corporation MISCELLANEOUS ADMINISTRATIVE MOTION TO FILE UNDER SEAL PSYSTAR'S OPPOSITION TO APPLE'S MOTION TO SEAL APPLE'S MOTION FOR SUMMARY JUDGMENT (CV 08-03251 WHA) 2 Case3:08-cv-03251-WHA Document186 Filed10/13/09 Page3 of 3 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 CERTIFICATE OF SERVICE I, Michael Wilson, declare I am employed in the City of Houston and County of Harris, Texas in the office of Camara & Sibley. I am over the age of eighteen and not a party to this action. My business address is Camara & Sibley, 2339 University Boulevard, Houston, Texas 77005. I served the following document(s): MISCELLANEOUS ADMINISTRATIVE MOTION TO FILE UNDER SEAL PSYSTAR'S OPPOSITION TO APPLE'S MOTION TO SEAL APPLE'S MOTION FOR SUMMARY JUDGMENT Case No. CV 08-03251 WHA on the interested parties in this action by placing a true and correct copy thereof, on the above date, enclosed in a sealed envelope, following the ordinary business practice of Camara & Sibley LLP. I sent the document(s) to the following: James G. Gilliland, Jr. TOWNSEND AND TOWNSEND AND CREW LLP Two Embarcadero Center, 8th Floor San Francisco, California 94111 Telephone: (415) 576-0200 Facsimile: (415) 576-0300 email: jggilliland@townsend.com [By First Class Mail] I am readily familiar with my employer's practice for collecting and processing documents for mailing with the United States Postal Service. On the date listed herein, following ordinary business practice, I served the within document(s) at my place of business, by placing a true copy thereof, enclosed in a sealed envelope, with postage thereon fully prepaid, for collection and mailing with the United States Postal Service where it would be deposited with the United States Postal Service that same day in the ordinary course of business. [By Overnight Courier] I caused each envelope to be delivered by a commercial carrier service for overnight delivery to the offices of the addressee(s). [By Hand] I directed each envelope to the party(ies) so designated on the service list to be delivered by courier this date. [By Facsimile Transmission] I caused said document to be sent by facsimile transmission to the fax number indicated for the party(ies) listed above. [By Electronic Transmission] I caused said document to be sent by electronic transmission to the e-mail address indicated for the party(ies) listed above via the court's ECF notification system. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct, and that this declaration was executed on October 12, 2009 at Houston, Texas. /s/ Michael Wilson Michael Wilson MISCELLANEOUS ADMINISTRATIVE MOTION TO FILE UNDER SEAL PSYSTAR'S OPPOSITION TO APPLE'S MOTION TO SEAL APPLE'S MOTION FOR SUMMARY JUDGMENT (CV 08-03251 WHA) 3

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