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 Att. 1

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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 C. 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, DECLARATION OF STEWART KELLAR IN SUPPORT OF ADMINISTRATIVE Plaintiff, MOTION TO FILE UNDER SEAL EXHIBIT A TO DECLARATION OF ALEX v. STAMOS; AND EXHIBIT F TO DECLARATION OF STEWART KELLAR IN REGEORGE HOTZ, et al., PLY TO SONY'S OPPOSITION TO DEFENDANT HOTZ'S MOTION TO Defendants. DISMISS Date: April 8, 2011 Time: 9:00 am Courtroom: 10, 19th Floor Judge: Hon. Susan Illston

DECLARATION OF STEWART KELLAR (No. 11-CV-00167-SI) Dockets.Justia.com

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I, Stewart Kellar, declare: 1. I am counsel of record for Mr. George Hotz in the above-captioned matter.

I have personal knowledge of the facts stated in this declaration, unless otherwise indicated, and could and would testify competently thereto. 2. Exhibit F 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. 3. Exhibit 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. 4. Mr. Hotz's request is narrowly tailored to seal only those materials for

which good cause to seal has been established.

I declare under penalty of perjury on this date under the laws of the United States of America in San Francisco, California that the foregoing is true and correct.

Dated: March 25, 2011. /s/ Stewart Kellar Stewart Kellar
4841-7608-3208, v. 2

DECLARATION OF STEWART KELLAR (NO. 11-CV-000167 SI)