FreecycleSunnyvale v. The Freecycle Network

Filing 120

Declaration of Lisa Kobialka in Support of 119 Amended MOTION for Leave to File Documents Under Seal filed byThe Freecycle Network. (Related document(s) 119 ) (Kobialka, Lisa) (Filed on 9/18/2007)

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FreecycleSunnyvale v. The Freecycle Network Doc. 120 Case 4:06-cv-00324-CW Document 120 Filed 09/18/2007 Page 1 of 2 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 PAUL J. ANDRE, Bar No. 196585 (pandre@perkinscoie.com) LISA KOBIALKA, Bar No. 191404 (lkobialka@perkinscoie.com) ESHA BANDYOPADHYAY, Bar. No. 212249 (ebandyopadhyay@perkinscoie.com) SEAN M. BOYLE, Bar No. 238128 (sboyle@perkinscoie.com) PERKINS COIE LLP 101 Jefferson Drive Menlo Park, CA 94025 Telephone: (650) 838-4300 Facsimile: (650) 838-4350 Attorneys for Defendant The Freecycle Network, Inc. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION FREECYCLESUNNYVALE, a California unincorporated association, Plaintiff, v. THE FREECYCLE NETWORK, INC., an Arizona corporation, Defendant. CASE NO. C 06-00324 CW AMENDED DECLARATION OF LISA KOBIALKA IN SUPPORT OF THE FREECYCLE NETWORK, INC.'S AMENDED NOTICE OF ADMINISTRATIVE MOTION AND MOTION FOR LEAVE TO FILE DOCUMENTS UNDER SEAL Date: Time: Before: Location: September 27, 2007 2:00 p.m. Honorable Claudia Wilken Courtroom 2 THE FREECYCLE NETWORK, INC. an Arizona corporation, Counterclaimant, v. FREECYLESUNNYVALE, a California unincorporated association, Counterdefendant. AMENDED DECLARATION OF LISA KOBIALKA IN SUPPORT OF THE FREECYCLE NETWORK'S AMENDED MOTION TO SEAL -1- CASE NO. C 06-00324 CW Dockets.Justia.com Case 4:06-cv-00324-CW Document 120 Filed 09/18/2007 Page 2 of 2 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 I, Lisa Kobialka, hereby declare as follows: 1. I am an attorney with the law firm of Perkins Coie LLP, counsel for Defendant and Counterclaimant The Freecycle Network, Inc. (The Freecycle Network") in the above-captioned action. I am a member of the Bar of the State of California and this Court. I have personal knowledge of the facts set forth in this Declaration, and if called upon to do so, could testify competently thereto. 2. I submit this declaration in support of The Freecycle Network's Amended Administrative Motion and Motion for Leave to File Documents Under Seal. 3. I have reviewed the following documents and determined that they contain information that The Freecycle Network considers to be confidential, proprietary, and/or trade secret information: 1. EXHIBITS 1, 3-5, 9-14, 16, 18-20, 26, 28-31, 33-39, 47, 50, 54, 56, 5859, 61, 66-69, 71-72, 74, 76-89, 90-94, 97-101, 103 AND 105-109 TO THE DECLARATION OF LISA KOBIALKA IN SUPPORT OF THE FREECYCLE NETWORK, INC.'S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF'S MOTION FOR SUMMARY ADJUDICATION UNDER FED.R.CIV.P. 56; EXHIBITS 8-11, 13, 15-16, 20 AND 23-43 TO THE DECLARATION OF DERON BEAL IN SUPPORT OF THE FREECYCLE NETWORK, INC.'S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF'S MOTION FOR SUMMARY ADJUDICATION UNDER FED.R.CIV.P. 56. 2. 4. These documents are not available to the general public, and only certain members of The Freecycle Network have access to them. See Declaration of Deron Beal in Support of The Freecycle Network's Amended Notice of Administrative Motion and Motion for Leave to File Documents Under Seal filed herewith, 2-3. I declare under penalty of perjury under the laws of the State of California and the United States that each of the above statements is true and correct. Executed on September 18, 2007, in Menlo Park, California. /s/ Lisa Kobialka Lisa Kobialka AMENDED DECLARATION OF LISA KOBIALKA IN SUPPORT OF THE FREECYCLE NETWORK'S AMENDED MOTION TO SEAL -2- CASE NO. C 06-00324 CW

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