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

Filing 246

Plaintiffs' MOTION to Seal Document Exhibits K, L-1 AND M-1 to the Declaration of Theresa Sutton in Support of Plaintiff's Response to Finnegan's Motion to Withdraw as Counsel for Defendant Winston Williams 245 filed by Mark Zuckerberg, The Facebook, Inc. (Sutton, Theresa) (Filed on 1/2/2008) Text modified on 1/3/2008 (bw, COURT STAFF).

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

Doc. 24

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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] m 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), PACIFIC NORTHWEST SOFTWARE, INC., WINSTON WILLIAMS, WAYNE CHANG, and DAVID GUCWA AND DOES 1-25, Defendants.

Case No. 5:07-CV-01389-RS PLAINTIFFS' MOTION TO SEAL EXHIBITS K, L-1, AND M-1 TO THE DECLARATION OF THERESA SUTTON IN SUPPORT OF PLAINTIFFS' RESPONSE TO FINNEGAN'S MOTION TO WITHDRAW AS COUNSEL FOR DEFENDANT WINSTON WILLIAMS Date: Time: Judge: January 28, 2007 9:30 A.M. Honorable Richard Seeborg

OHS West:260361710.2

FACEBOOK'S ADMINISTRATIVE REQUEST TO FILE EXHIBITS UNDER SEAL CASE NO. 5:07-CV-01389-RS

Dockets.Justia.com

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Pursuant to Civil L.R. 7-11 and 79-5 (d), Plaint iffs respectfully submit this motion asking the Court to file under seal Exhibits K, L-1 and M-1 to the Declaration of Theresa Sutton In Support of Plaintiffs' Response to Finnegan's Motion to Withdraw as Counsel for Defendant Winston Williams. 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 Confidential" pursuant to the Protective Order. Exhibit K to the Declaration of Theresa Sutton is a document produced by Pacific Northwest Software in this litigation. It has been marked Highly Confidential by PNS pursuant to the Protective Order entered in this matter, and hence is subject to Local Civil Rule 79-5(d). Facebook takes no position as to whether the deposition testimony of Winston Williams is confidential. Exhibit L-1 to the Declaration of Theresa Sutton is a copy of relevant excerpts from ConnectU's January 16, 2006, 30(b)(6) deposition. This transcript has been marked Highly Confidential by PNS pursuant to the Protective Order entered in that matter, and hence is subject to Local Civil Rule 79-5(d). Facebook takes no position as to whether this document is confidential. Exhibit M-1 to the Declaration of Theresa Sutton is a copy of relevant excerpts from Pacific Northwest Software's January 29, 2007, 30(b)(6) deposition. This transcript has been marked Highly Confidential by PNS pursuant to the Protective Order entered in that matter, and hence is subject to Local Civil Rule 79-5(d). Facebook takes no position as to whether this document is confidential. Dated: January 2, 2008 Orrick, Herrington & Sutcliffe LLP /s/ Theresa A. Sutton /s/ Theresa A. Sutton Attorneys for Plaintiffs FACEBOOK, INC. AND MARK ZUCKERBERG

OHS West:260361710.2

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PLAINTIFF'S ADMINISTRATIVE REQUEST TO FILE EXHIBITS UNDER SEAL CASE NO. 5:07-CV-01389-RS

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OHS West:260361710.2

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 January 2, 2008. Dated: January 2, 2008. Respect fully submitted, /s/ Theresa A. Sutton /s/ Theresa A. Sutton

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PLAINTIFF'S ADMINISTRATIVE REQUEST TO FILE EXHIBITS UNDER SEAL CASE NO. 5:07-CV-01389-RS