CLRB Hanson Industries, LLC et al v. Google Inc.

Filing 121

Declaration of M. Christopher Jhang in Support of 120 First MOTION to File Documents Under Seal filed by Google Inc.. (Attachments: # 1 Exhibit A)(Related document(s) 120 ) (Jhang, Christopher) (Filed on 5/7/2007) Modified on 5/7/2007 (cv, COURT STAFF).

CLRB Hanson Industries, LLC et al v. Google Inc.

Doc. 121

Case 5:05-cv-03649-JW

Document 121

Filed 05/07/2007

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DAVID T. BIDERMAN, Bar No. 101577 JUDITH B. GITTERMAN, Bar No. 115661 M. CHRISTOPHER JHANG, Bar No. 211463 PERKINS COIE LLP Four Embarcadero Center, Suite 2400 San Francisco, CA 94111-4131 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Email: [e-mail] Email: [e-mail] Attorneys for Defendant Google Inc.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

CLRB HANSON INDUSTRIES, LLC d/b/a INDUSTRIAL PRINTING, and HOWARD STERN, on behalf of themselves and all others similarly situated, Plaintiffs,

CASE NO. C O5-03649 JW DECLARATION OF M. CHRISTOPHER JHANG IN SUPPORT OF GOOGLE INC.'S MOTION FOR LEAVE TO FILE DOCUMENTS UNDER SEAL Date: Time: Dept.: Judge: June 11, 2007 9:00 a.m. Courtroom 8 Honorable James Ware

15 v. 16 GOOGLE, INC., 17 Defendant. 18 19 20 21 22 23 24 25 26 27 28

Jhang Declaration in Support of Google Inc.'s Motion for Leave to File Documents Under Seal CASE NO. 05-03649
41063-0023/LEGAL13215798.1

Dockets.Justia.com

Case 5:05-cv-03649-JW

Document 121

Filed 05/07/2007

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I, M. Christopher Jhang, hereby declare as follows: 1. I am an attorney duly licensed to practice law in all of the courts of the State of

California and this Court, and am an attorney with the law firm of Perkins Coie LLP, counsel for defendant Google Inc. ("Google") in this action. I submit this declaration in support of Google's Motion for Leave to File Documents Under Seal. I have personal knowledge of the facts set forth below except as to those matters stated on information and belief, and as to those matters, I believe them to be true. If called upon to testify, I could and would testify competently as to the matters set forth herein. 2. Attached as Exhibit A is a true and correct copy of the parties' [Proposed]

Stipulated Protective Order Regarding Confidential Information, filed with the Court on March 2, 2007. 3. I have reviewed the following documents and determined that they contain,

discuss, or refer to information or documents that Google considers to be confidential, proprietary, and/or trade secret information: 1. 2. GOOGLE INC.'S SUPPLEMENTAL BRIEF IN SUPPORT OF SUMMARY JUDGMENT MOTION; SUPPLEMENTAL DECLARATION OF M. CHRISTOPHER JHANG IN SUPPORT OF GOOGLE INC.'S SUPPLEMENTAL BRIEF IN SUPPORT OF SUMMARY JUDGMENT MOTION (INCLUDING EXHIBITS A-D)

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 May 7, 2007, in San Francisco, California. PERKINS COIE LLP

23 24 By: 25 26 27 28 -2Jhang Declaration in Support of Google Inc.'s Motion for Leave to File Documents Under Seal CASE NO. 05-03649
41063-0023/LEGAL13215798.1

/S/ M. Christopher Jhang