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

Filing 196

Plaintiffs' Administrative Request Pursuant to Local Civil Rule 79-5(b) and (D) to file Under Seal Exhibits LL, MM, NN, OO and PP) to the Supplemental Declaration of Theresa A. Sutton in Support of Plaintiffs' Opposition to Defendants' Motion to Dismiss ( 136 ) filed by Mark Zuckerberg, The Facebook, Inc.. Motion Hearing set for 10/10/2007 09:30 AM. (Sutton, Theresa) (Filed on 10/2/2007) Text modified on 10/3/2007, linkage added (bw, COURT STAFF).

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The Facebook, Inc. v. Connectu, LLC et al Doc. 196 Case 5:07-cv-01389-RS Document 196 Filed 10/02/2007 Page 1 of 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 G. HOPKINS GUY, III (State Bar No. 124811) hopguy@orrick.co m I. NEEL CHATTERJEE (State Bar No. 173985) nchatterjee@orrick.com MONTE COOPER (State Bar No. 196746) mcooper@orrick.co m THERESA A. SUTTON (State Bar No. 211857) tsutton@orrick.com YVONNE P. GREER (State Bar No. 214072) ygreer@orrick.co m ORRICK, HERRINGTON & SUTCLIFFE LLP 1000 Marsh Road Menlo Park, CA 94025 Telephone: 650-614-7400 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 AND DOES 1-25, Defendants. Case No. 5:07-CV-01389-RS PLAINTIFFS' ADMINISTRATIVE REQUEST PURSUANT TO LOCAL CIVIL RULE 79-5(B) & (D) TO FILE UNDER SEAL EXHIBITS LL, MM, NN, OO AND PP TO THE SUPPLEMENTAL 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:260312736.1 FACEBOOK'S ADMINISTRATIVE REQUEST TO FILE EXHIBITS UNDER SEAL CASE NO. 5:07-CV-01389-RS Dockets.Justia.com Case 5:07-cv-01389-RS Document 196 Filed 10/02/2007 Page 2 of 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Pursuant to Civil L.R. 7-11 and 79-5 (b), Facebook respectfully submits this administrative request asking the Court to file under seal Exhibits LL, MM, NN, OO, and PP to the Supplemental Declaration of Theresa A. Sutton filed in Support of Plaintiffs' Opposit ion to Defendants' Motion to Dismiss. The parties entered into, and the California Superior Court issued, a Stipulated Protective Order on January 23, 2006, which prohibits either party from filing in the public record any documents that have been designated as "Confidential" or "Highly Confident ial" pursuant to the Protective Order. Exhibit LL to the Supplemental Declaration of Theresa A. Sutton filed in Support of Plaintiffs' Opposit ion to Defendants' Motion to Dismiss is a copy of Defendant Divya Narendra's deposition taken on January 16, 2007. It has been marked Confidential by ConnectU pursuant to the Protective Order entered in this matter, and hence is subject to Local Civil Rule 79-5(d). Exhibit MM to the Supplemental Declaration of Theresa A. Sutton filed in Support of Plaintiffs' Opposit ion to Defendants' Motion to Dismiss is a copy of Defendant ConnectU, LLC's deposition taken on January 16, 2007. It has been marked Confidential by ConnectU pursuant to the Protective Order entered in this matter, and hence is subject to Local Civil Rule 79-5(d). Exhibit NN to the Supplemental Declaration of Theresa A. Sutton filed in Support of Plaintiffs' Opposit ion to Defendants' Motion to Dismiss is a copy of Defendant Cameron Winklevoss' deposition taken on January 16, 2007. It has been marked Confidential by ConnectU pursuant to the Protective Order entered in this matter, and hence is subject to Local Civil Rule 79-5(d). Exhibit OO to the Supplemental Declaration of Theresa A. Sutton filed in Support of Plaintiffs' Opposit ion to Defendants' Motion to Dismiss is a copy of Defendant Tyler Winklevoss' deposition taken on January 16, 2007. It has been marked Confidential by ConnectU pursuant to the Protective Order entered in this matter, and hence is subject to Local Civil Rule 79-5(d). Exhibit PP to the Supplemental Declaration of Theresa A. Sutton filed in Support of Plaintiffs' Opposit ion to Defendants' Motion to Dismiss is a copy of Defendant Howard OHS West:260312736.1 -2- PLAINTIFF'S ADMINISTRATIVE REQUEST TO FILE EXHIBITS UNDER SEAL CASE NO. 5:07-CV-01389-RS Case 5:07-cv-01389-RS Document 196 Filed 10/02/2007 Page 3 of 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Winklevoss' deposition taken on January 16, 2007. It has been marked Confidential by ConnectU pursuant to the Protective Order entered in this matter, and hence is subject to Local Civil Rule 79-5(d). Dated: October 2, 2007 Orrick, Herrington & Sutcliffe LLP /s/ Theresa A. Sutton /s/ Theresa A. Sutton Attorneys for Plaintiffs FACEBOOK, INC. AND MARK ZUCKERBERG OHS West:260312736.1 -3- PLAINTIFF'S ADMINISTRATIVE REQUEST TO FILE EXHIBITS UNDER SEAL CASE NO. 5:07-CV-01389-RS Case 5:07-cv-01389-RS Document 196 Filed 10/02/2007 Page 4 of 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 OHS West:260312736.1 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 October 2, 2007. Dated: October 2, 2007. Respect fully submitted, /s/ Theresa A. Sutton /s/ Theresa A. Sutton -4- PLAINTIFF'S ADMINISTRATIVE REQUEST TO FILE EXHIBITS UNDER SEAL CASE NO. 5:07-CV-01389-RS

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