The Facebook, Inc. v. Connectu, Inc et al

Filing 104

Defendants' Administrative Motion to File Under Seal Exhibits A, B, and D to the Declaration of Scott R. Mosko in Support of Defendants' Repl; [Proposed] Order re 100 filed by Pacific Northwest Software, Inc., Winston Williams. (Mosko, Scott) (Filed on 7/6/2007) Text modified on 7/10/2007 to conform to document caption post by counsel (bw, COURT STAFF).

The Facebook, Inc. v. Connectu, LLC et al

Doc. 104

Case 5:07-cv-01389-RS

Document 104

Filed 07/06/2007

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Scott R. Mosko (State Bar No. 106070) FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. Stanford Research Park 3300 Hillview Avenue Palo Alto, California 94304 Telephone: [phone] Facsimile: [phone] Attorney for Defendants Pacific Northwest Software, Inc. and Winston Williams

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION FACEBOOK, INC., and MARK ZUCKERBERG, Plaintiffs, v. CONNECTU LLC, (now known as CONNECTU, INC.), CAMERON WINKLEVOSS, TYLER WINKLEVOSS, DIVYA NARENDRA, PACIFIC NORTHWEST SOFTWARE, INC., WINSTON WILLIAMS, WAYNE CHANG, DAVID GUCWA, and DOES 1-25, Defendants. CASE NO. C 07-01389 RS DEFENDANTS' ADMINISTRATIVE MOTION TO FILE UNDER SEAL EXHIBITS A, B, AND D TO THE DECLARATION OF SCOTT R. MOSKO IN SUPPORT OF DEFENDANTS' REPLY [PROPOSED] ORDER Date: Time: Dept.: Judge: July 11, 2007 9:30 a.m. 4 Hon. Richard Seeborg

DEFENDANTS' ADMINISTRATIVE MOTION AND [PROPOSED] ORDER TO FILE DOCUMENTS UNDER SEAL Case No. 5:07-CV-01389-RS

Dockets.Justia.com

Case 5:07-cv-01389-RS

Document 104

Filed 07/06/2007

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ADMINISTRATIVE MOTION FOR FILING UNDER SEAL Papers Submitted For Filing Under Seal in Their Entireties

Pursuant to Civil Local Rules 7-11 and 79-5(b), Defendants respectfully hereby request leave of Court to file under seal in their entireties the following documents being lodged with the Clerk: EXHIBITS A, B, AND D TO THE DECLARATION OF SCOTT R. MOSKO IN SUPPORT OF DEFENDANTS' REPLY (FILED UNDER SEAL IN THEIR ENTIRETIES) Exhibit A includes deposition testimony in a deposition marked "Highly Confidential" or "Confidential" under the protective order. Exhibit B is a publicly filed document that Plaintiffs marked as confidential. Defendants requested that Plaintiffs allow this document to be publicly filed. Plaintiffs refused. Exhibit D is supplemental responses to discovery that Plaintiffs have designated highly confidential. As required by Civil Local Rule 79-5(b), Defendants are lodging with the Clerk copies of the documents which have been designated "Highly Confidential" and "Confidential" (for filing under seal). SUPPORTING DECLARATION OF SCOTT R. MOSKO I, Scott R. Mosko, declare as follows: 1. I am an attorney admitted to practice in the State of California and the United States

District Court for the Northern District of California, and a partner of Finnegan, Henderson, Farabow, Garrett & Dunner, L.L.P., attorneys of record for Defendants Pacific Northwest Software and Winston Williams. The matters referred to in this declaration are based on my personal knowledge and if called as a witness I could, and would, testify competently to those matters. 2. The representations made above in this Administrative Motion are true and correct to

the best of my knowledge and belief. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct and that this declaration was executed this 6th day of July, 2007, at Palo Alto, California. By: Scott R. Mosko 1 /s/
DEFENDANTS' ADMINISTRATIVE MOTION AND [PROPOSED] ORDER TO FILE DOCUMENTS UNDER SEAL Case No. 5:07-CV-01389-RS

Case 5:07-cv-01389-RS

Document 104

Filed 07/06/2007

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[PROPOSED] ORDER Upon good cause shown, IT IS HEREBY ORDERED that the following documents shall be received and filed under seal in their entireties by the Clerk: Exhibits A, B, and D to the Declaration of Scott R. Mosko in Support of Defendants Pacific Northwest Software, Inc.'s and Winston Williams's Reply to Plaintiffs' Opposition to Defendants' Opposition to Dismiss for Lack of Personal Jurisdiction.

__________________________ United States Magistrate Judge

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DEFENDANTS' ADMINISTRATIVE MOTION AND [PROPOSED] ORDER TO FILE DOCUMENTS UNDER SEAL Case No. 5:07-CV-01389-RS