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

Filing 159

MOTION to Seal Exhibits C, E, L, M, O, U, X and CC to The Declaration of Theresa Sutton (Docket # 158) filed by Mark Zuckerberg, The Facebook, Inc. (Attachments: # 1 Declaration # 2 Proposed Order)(Sutton, Theresa) (Filed on 9/19/2007) Text Modified on 9/20/2007 (bw, COURT STAFF).

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

Doc. 159 Att. 1

Case 5:07-cv-01389-RS

Document 159-2

Filed 09/19/2007

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G. HOPKINS GUY, III (State Bar No. 124811) [e-mail] m I. NEEL CHATTERJEE (State Bar No. 173985) [e-mail] MONTE COOPER (State Bar No. 196746) [e-mail] m THERESA A. SUTTON (State Bar No. 211857) [e-mail] YVONNE P. GREER (State Bar No. 214072) [e-mail] ORRICK, HERRINGTON & SUTCLIFFE LLP 1000 Marsh Road Menlo Park, CA 94025 Telephone: [phone] Facsimile: 650-614-7401 Attorneys for Plaintiffs FACEBOOK, INC. and MARK ZUCKERBERG UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

FACEBOOK, INC. and MARK ZUCKERBERG, Plaint iffs, v. CONNECTU, INC. (formerly known as CONNECTU, LLC), CAMERON WINKLEVOSS, TYLER WINKLEVOSS, DIVYA NARENDRA, PACIFIC NORTHWEST SOFTWARE, INC., WINSTON WILLIAMS, WAYNE CHANG, and DAVID GUCWA, Defendants.

Case No. 5:07-CV-01389-RS DECLARATION OF YVONNE P. GREER IN SUPPORT OF SEALING EXHIBIT CC TO THE DECLARATION OF THERESA A. SUTTON IN SUPPORT OF PLAINTIFFS' OPPOSITION TO DEFENDANTS' MOTION TO DISMISS Date: Time: Judge: October 10, 2007 9:30 A.M. Honorable Richard Seeborg

OHS West:260305738.1

GREER DECL. ISO SEALING EXHIBITS TO THE SUTTON DECLARATION ISO OPPOSITION TO MOTION TO DISMISS 5:07-CV-01389-RS

Dockets.Justia.com

Case 5:07-cv-01389-RS

Document 159-2

Filed 09/19/2007

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I, Yvonne P. Greer, declare as follows: 1. I am an associate at the law firm of Orrick, Herrington & Sutcliffe, counsel for

Plaintiffs Facebook, Inc. and Mark Zuckerberg in this action, and a member of the bar of the state of California. I make this declaration in support of Facebook's Administrative Request Pursuant to Local Civil Rule 79-5(b) to File Under Seal Exhibit CC to the Declaration of Theresa A. Sutton in Support of Plaintiffs' Opposition to Defendants' Motion to Dismiss. I make this declaration of my own personal knowledge and, if called as a witness, I could and would testify competently to the truth of the matters set forth herein. 2. Exhibit CC to the Declaration of Theresa A. Sutton filed in Support of Plaintiffs'

Opposition to Defendants' Motion to Dismiss is a copy of Facebook's Motions to Compel filed in the Superior Court for the County of Santa Clara action, Case No. 1:05-CV-047381. These motions contain references to documents and deposition testimony produced by ConnectU that ConnectU marked Confidential. Accordingly, the Motions to Compel were marked Confidential by Facebook pursuant to the Protective Order entered in that matter. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Executed this 19th day of September, 2007, at Menlo Park, California. /s/ Yvonne P. Greer /s/

Filer's Attestation: Pursuant to General Order No. 45, §X(B), I attest under penalty of perjury that concurrence in the filing of the document has been obtained from its signatory. Dated: September 19, 2007 Respect fully submitted, /s/ Theresa A. Sutton /s/ Theresa A. Sutton

OHS West:260305738.1

GREER DECL. ISO SEALING EXHIBITS TO THE SUTTON DECLARATION ISO OPPOSITION TO MOTION TO DISMISS 5:07-CV-01389-RS

Case 5:07-cv-01389-RS

Document 159-2

Filed 09/19/2007

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OHS West:260305738.1

CERTIFICATE OF SERVICE I hereby certify that this document(s) filed through the ECF system will be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF) and paper copies will be sent to those indicated as non registered participants on September 19, 2007. Dated: September 19, 2007. Respect fully submitted, /s/ Theresa A. Sutton /s/ Theresa A. Sutton

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GREER DECL. ISO SEALING EXHIBITS TO THE SUTTON DECLARATION ISO OPPOSITION TO MOTION TO DISMISS 5:07-CV-01389-RS