Google, Inc. v. Affinity Engines, Inc.

Filing 20

Google, Inc. v. Affinity Engines, Inc.

Doc. 20

Case 5:05-cv-00598-JW

Document 20

Filed 04/18/2005

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JAMES A. DIBOISE, State Bar No. 83296 ([e-mail]) COLLEEN BAL, State Bar No. 167637 ([e-mail]) WILSON SONSINI GOODRICH & ROSATI Professional Corporation 650 Page Mill Road Palo Alto, CA 94304-1050 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff Google Inc. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

GOOGLE INC.,

v. AFFINITY ENGINES, INC.,

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

CASE NO.: C-05-00598 JW (HRL) DECLARATION OF COLLEEN BAL IN SUPPORT OF PLAINTIFF GOOGLE INC.'S MISCELLANEOUS ADMINISTRATIVE REQUEST TO FILE DOCUMENTS UNDER SEAL PURSUANT TO CIVIL LOCAL RULES 7-10(b) AND 79-5 Date: Time: Judge: Courtroom: May 9, 2005 9:00 a.m. Honorable James Ware 8, 4th Floor

DECL. ISO GOOGLE'S MISC. ADMIN. REQUEST TO FILE UNDER SEAL - CASE NO.: 05-00598 JW (HRL)

2633966_1.DOC

Dockets.Justia.com

Case 5:05-cv-00598-JW

Document 20

Filed 04/18/2005

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I, Colleen Bal, declare as follows: 1. I am an attorney at law duly licensed to practice in the State of California and

before this Court. I am a member of Wilson Sonsini Goodrich & Rosati, counsel for defendant and counterclaimant Google Inc. ("Google"). I have personal knowledge of the facts set forth herein and, if called as a witness, could and would testify competently thereto. 2. I submit this declaration in support of Google's Miscellaneous Administrative

Request to File Under Seal, Pursuant to Local Rules 7-10(b) and 79-5, Exhibits A and B to the Declaration of David H. Kramer In Support of Google Inc.'s Opposition to Affinity Engines, Inc.'s Motion to Dismiss and/or Stay Proceedings ("Kramer Declaration"). 3. The documents attached as Exhibits A and B to the Kramer Declaration were

produced by Google in the state court action Affinity Engines, Inc. v. Google Inc., Santa Clara County Superior Court, Case No. 104CV020368. They contain employment information concerning one of Google's employees. Exhibits A and B have been designated "Highly Confidential ­ Attorneys' Eyes Only" pursuant to the Protective Order entered in that matter on August 23, 2004. 4. In light of the designation, Google requests an order permitting it to file Exhibits

A and B to the Kramer Declaration under seal.

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on April 18, 2005, at Palo Alto, California. /s/ Colleen Bal Colleen Bal

DECL. ISO GOOGLE'S MISC. ADMIN. REQUEST TO FILE UNDER SEAL - CASE NO.: 05-00598 JW (HRL)

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