Oracle America, Inc. v. Google Inc.

Filing 150

Administrative Motion to File Under Seal Exhibits A, B and D to Declaration of Dorian Daley #149 filed by Oracle America, Inc.. Motion Hearing set for 5/31/2011 11:30 AM in Courtroom 4, 3rd Floor, Oakland before Magistrate Judge Donna M. Ryu. (Attachments: #1 Affidavit Declaration of Daniel Muino, #2 Proposed Order)(Muino, Daniel) (Filed on 5/26/2011) Modified on 6/1/2011 (ig, COURT STAFF).

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MORRISON & FOERSTER LLP
MICHAEL A. JACOBS (Bar No. 111664)
[e-mail]
MARC DAVID PETERS (Bar No. 211725)
[e-mail]
DANIEL P. MUINO (Bar No. 209624)
[e-mail]
755 Page Mill Road
Palo Alto, CA 94304-1018
Telephone: [phone] / Facsimile: [phone]

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BOIES, SCHILLER & FLEXNER LLP
DAVID BOIES (Admitted Pro Hac Vice)
[e-mail]
333 Main Street
Armonk, NY 10504
Telephone: [phone] / Facsimile: [phone]
STEVEN C. HOLTZMAN (Bar No. 144177)
[e-mail]
1999 Harrison St., Suite 900
Oakland, CA 94612
Telephone: [phone] / Facsimile: [phone]

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ORACLE CORPORATION
DORIAN DALEY (Bar No. 129049)
[e-mail]
DEBORAH K. MILLER (Bar No. 95527)
[e-mail]
MATTHEW M. SARBORARIA (Bar No. 211600)
[e-mail]
500 Oracle Parkway
Redwood City, CA 94065
Telephone: [phone] / Facsimile: [phone]
Attorneys for Plaintiff
ORACLE AMERICA, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ORACLE AMERICA, INC.

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Plaintiff,

DECLARATION OF DANIEL P.
MUINO IN SUPPORT OF
PLAINTIFF’S ADMINISTRATIVE
REQUEST TO FILE DOCUMENTS
UNDER SEAL

Defendant.

Date: May 31, 2011
Time: 11:30 a.m.
Dept.: Courtroom 4, 3rd Floor
Judge: Honorable Donna M. Ryu

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v.

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GOOGLE INC.

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Case No. CV 10-03561 WHA

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MUINO DECL. ISO PLAINTIFF’S ADMINISTRATIVE REQUEST TO FILE DOCUMENTS UNDER SEAL
CASE NO. CV 10-03561 WHA
pa-1466903

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I, Daniel P. Muino, declare as follows:

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I am an attorney with the law firm of Morrison & Foerster LLP, counsel of record

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for Plaintiff Oracle America, Inc. (“Oracle”). I am an attorney duly licensed to practice law in the

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courts of the State of California and am a member of the Bar of this Court. I make this

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declaration in support of Plaintiff’s Administrative Request To File Documents Under Seal. This

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declaration is based on my personal knowledge, unless otherwise stated, and if called as a witness

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I could and would testify competently to the facts stated herein.

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2.

Exhibit A to the Declaration of Dorian Daley in Support of Oracle’s Request for

Access to Attorneys’ Eyes Only Information should be filed under seal. This Exhibit is the

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declaration of Oracle’s co-president, Safra Catz, it was filed under seal in the litigation matter

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Oracle Corp, et al. v. SAP AG, et al., Case No. 07-1658 (N.D. Cal.). This Exhibit is being filed

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under seal in good faith and Pursuant to Civil Local Rule 79-5. This Exhibit contains Oracle’s

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sensitive confidential information.

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3.

Exhibit B to the Declaration of Dorian Daley in Support of Oracle’s Request for

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Access to Attorneys’ Eyes Only Information should be filed under seal. This Exhibit is Oracle’s

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Opposition to Defendants’ Motion to Compel No. 3, from the Oracle Corp, et al. v. SAP AG, et

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al., Case No. 07-1658 (N.D. Cal.) case where it was filed under seal. This Exhibit is being filed

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under seal in good faith and Pursuant to Civil Local Rule 79-5. This Exhibit contains Oracle’s

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sensitive confidential information.

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4.

Exhibit D to the Declaration of Dorian Daley in Support of Oracle’s Request for

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Access to Attorneys’ Eyes Only Information should be filed under seal. This Exhibit is

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Ms. Daley's statement delivered at an unofficial meeting of the Java Community Process, which

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was a confidential proceeding. This Exhibit is being filed under seal in good faith and Pursuant

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to Civil Local Rule 79-5.

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///

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///

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///

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///
MUINO DECL. ISO PLAINTIFF’S ADMINISTRATIVE REQUEST TO FILE DOCUMENTS UNDER SEAL
CASE NO. CV 10-03561 WHA
pa-1466903

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I declare under penalty of perjury under the laws of the United States that to the best of
my knowledge the foregoing is true and correct.
Executed on May 26, 2011 at Boston, Massachusetts.

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/s/ Daniel P. Muino
Daniel P. Muino

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MUINO DECL. ISO PLAINTIFF’S ADMINISTRATIVE REQUEST TO FILE DOCUMENTS UNDER SEAL
CASE NO. CV 10-03561 WHA
pa-1466903

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