Sony Computer Entertainment America LLC v. Hotz et al

Filing 116

Administrative Motion to File Under Seal Exhibits F and M of Declaration of Kellar filed by George Hotz. (Attachments: # 1 Affidavit of Kellar, # 2 Proposed Order Granting Motion to Seal)(Kellar, Stewart) (Filed on 3/25/2011)

Sony Computer Entertainment America LLC v. Hotz et al

Doc. 116

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YASHA HEIDARI (Admitted Pro Hac Vice) [e-mail] Heidari Power Law Group LLC PO Box 79217 Atlanta, Georgia 30357 STEWART KELLAR (SBN 267747) [e-mail] E-ttorney at Law 148 Townsend Street, Suite 2 San Francisco, California 94107 Telephone: [phone] JACK PRAETZELLIS (SBN 267765) [e-mail] MBV LAW LLP 855 Front Street San Francisco, California 94111 Telephone: [phone] Facsimile: 415-989-5143 Attorneys for Defendant George Hotz UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

SONY COMPUTER ENTERTAINMENT Case No. 11-CV-000167 SI AMERICA LLC, a Delaware limited liability company, ADMINISTRATIVE MOTION TO FILE UNDER SEAL EXHIBIT A TO DECLAPlaintiff, RATION OF ALEX STAMOS AND EXHIBIT F TO DECLARATION OF v. STEWART KELLAR IN REPLY TO SONY'S OPPOSITION TO DEFENDANT GEORGE HOTZ, et al., HOTZ'S MOTION TO DISMISS Defendants. Date: April 8, 2011 Time: 9:00 am Courtroom: 10, 19th Floor Judge: Hon. Susan Illston

24045.01/4822-3543-7832

ADMINISTRATIVE MOTION TO FILE UNDER SEAL (No. 11-CV-00167-SI) Dockets.Justia.com

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Pursuant to Local Rules 7-11 and 79-5, Defendant George Hotz submits this Administrative Motion to file under seal Exhibit A to Declaration of Alex Stamos, and Exhibit F to the Declaration of Stewart Kellar in Reply to SCEA's opposition to Mr. Hotz's Motion to Dismiss for Lack of Personal Jurisdiction and Improper Venue. Pursuant to Local Rule 79-5 (c) (3), Mr. Hotz is lodging with the Clerk a copy of these documents for filing under seal. This motion is supported by the Declaration of Stewart Kellar ("Kellar Dec.") filed concurrently. Exhibit F to the Stewart Kellar Declaration were produced by SCEA to Mr. Hotz's counsel as HIGHLY CONFIDENTIAL ­ ATTORNEY'S EYES ONLY. Although counsel for Mr. Hotz contests this designation and believes these documents should be made part of the public record, pursuant to a pending Protective Order between the parties, the designation will remain at this time for purposes of filing these documents. Exhibits M to the Stewart Kellar Declaration was produced by SCEA to Mr. Hotz's counsel as HIGHLY CONFIDENTIAL ­ ATTORNEY'S EYES ONLY. Although counsel for Mr. Hotz contests this designation and believes these documents should be made part of the public record, pursuant to a pending Protective Order between the parties, the designation will remain at this time for purposes of filing these documents. Mr. Hotz's request is narrowly tailored to seal only those materials for which good cause to seal has been established. Accordingly, Mr. Hotz respectfully requests that the Court grant its Administrative Motion to file Exhibit A to Declaration of Alex Stamos, and Exhibit F to the Declaration of Stewart Kellar under seal.

Respectfully Submitted, Dated: March 25, 2011. MBV LAW LLP

By

/s/ Stewart Kellar Stewart Kellar

Attorneys for Defendant George Hotz -224045.01/4822-3543-7832, v. 1

ADMINISTRATIVE MOTION TO FILE UNDER SEAL (NO. 11-CV-000167 SI)