Google Inc. v. American Blind & Wallpaper Factory, Inc.
Filing
320
Notice of MOTION and Motion for Administrative Relief Seeking an Order Sealing Documents for Filing in Relation to Google's Response to ABWF's Four Declarations Regarding ANWF's Alleged preservation, Collection, and Production of Materials in Response to April 27, 2007 Court Order filed by Google Inc. (Krishnan, Ajay) (Filed on 5/25/2007) Text modified on 5/29/2007 to conform to document caption post by counsel (bw, COURT STAFF).
Google Inc. v. American Blind & Wallpaper Factory, Inc.
Doc. 320
Case 5:03-cv-05340-JF
Document 320
Filed 05/25/2007
Page 1 of 2
1 KEKER & V AN NEST, LLP
MICHAEL H. PAGE - #154913 2 MARK A. LEMLEY - #155830 KLAUS H. HAMM - #224905 3 AJAY S. KRSHNAN - #222476 710 Sansome Street
4 San Francisco, CA 94111-1704
Telephone: (415) 391-5400
5 Facsimile: (415) 397-7188
6
Attorneys. for Plaintiff and Counter Defendant 7 GOOGLE INC.
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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GOOGLE INC., a Delaware corporation,
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Case No. C 03-5340-JF (RS)
Plaintiff,
13
v. 14
15 FACTORY,
AMERICAN BLIND & W ALLP APER INC., a Delaware corporation
d/b/a decoratetoday.com, Inc., and DOES 1-
16 100, inclusive,
17 Defendants.
18
NOTICE OF MOTION AND MOTION FOR ADMINISTRATIVE RELIEF SEEKING AN ORDER SEALING DOCUMENTS FOR FILING IN RELATION TO GOOGLE'S RESPONSE TO ABWF'S FOUR DECLARATIONS REGARDING ABWF'S ALLEGED PRESERVATION, COLLECTION, AND PRODUCTION OF MATERIALS IN RESPONSE TO APRIL 27, 2007 COURT ORDER
AMERICAN BLIND & W ALLP APER 19 FACTORY, INC., a Delaware corporation
d/b/a decoratetoday.com, Inc.,
Hon. Richard Seeborg
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Counter-Plaintiff,
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v.
22 GOOGLE INC.,
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Counter-Defendant.
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25
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SEEKING AN ORDER SEALING FILING IN RELATION TO GOOGLE'S RESPONSE TO ABWF'S FOUR DECLARA TIONS REGARDING ABWF'S ALLEGED PRESERVATION, COLLECTION, AND PRODUCTION OF MATERILS IN RESPONSE TO APRIL 27,2007 COURT ORDER
NOTICE OF MOTION AND MOTION FOR ADMINISTRATIVE RELIEF DOCUMENTS FOR
396106.01
CASE NO. C 03-5340-JF (RS)
Dockets.Justia.com
Case 5:03-cv-05340-JF
Document 320
Filed 05/25/2007
Page 2 of 2
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NOTICE OF MOTION AND MOTION FOR ADMINISTRATIVE RELIEF SEALING DOCUMENTS
2
3 TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
4 Pursuant to Civil Local Rules 79-5(d) and 7-11 (a), Plaintiff and Counter-Defendant
5 Google Inc. ("Go
ogle") hereby gives notice to all counsel of record of its Motion for
6 Administrative Relief Seeking an Order Sealing Documents For Filing in Relation to Google' s
7 Response to ABWF's Four Declarations RegardingABWF's Alleged Preservation, Collection,
8 and Production of Materials in Response to April
27, 2007 Court Order ("Administrative
Motion, Google requests an order sealing Exhibit A to
9 Motion"). By way of this Administrative
10 the Declaration of Ajay Krishnan ("Krishnan Declaration") that was designated "Attorneys'
11 Eyes Only" by American Blind & Wallpaper Factory, Inc. ("ABWF") pursuant to the Stipulated
12 Protective Order signed by all parties to this litigation and approved by the Cour on September
13 19,2005 ("Protective Order") (Docket Item No. 60). Exhibit A is a document produced by
14 ABWF in the course of discovery, and Bates labeled ABWF 047376-047377.
15 Pursuant to Local Rules 79-5( d), Google moves to file under seal Exhibit A to the
16 Krishnan Declaration. Pursuant to Civil Local Rule 79-5(d), Exhibit A is lodged with the Clerk
17 concurently with this Administrative Motion.
18 Local Rule 79-5(d) outlines the procedure that ABWF must follow within five days ofthe
19 filing of this Administrative Motion if it wishes to maintain the confidential designation of
20 Exhibit A.
21 Dated: May 25,2007
KEKER & V AN NEST, LLP
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By: /s/ Ajay S. Krishnan AJA Y S. KRSHNAN Attorneys for Plaintiff and Counter Defendant
GOOGLE INC.
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28 1
NOTICE OF MOTION AND MOTION FOR ADMINISTRATIVE RELIEF SEEKING AN ORDER SEALING FILING IN RELATION TO GOOGLE'S RESPONSE TO ABWF'S FOUR DOCUMENTS FOR DECLARATIONS REGARDING ABWF' S ALLEGED PRESERVATION, COLLECTION, AND PRODUCTION
CASE NO. C 03-5340-JF (RS)
396106.01 OF MATERIALS IN RESPONSE TO APRIL 27, 2007 COURT ORDER
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