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

Filing 328

MOTION to Seal Exhibits B-D to the Declaration of Yvonne Greer Submitting Supplemental Evidence in Support of Plaintiffs' Motion for Partial summary Judgment re 251 ; and Motion to Compel Compliance by Defendants pacific Northwest Software and Winston Williams 271 (Greer Declaration) filed by Mark Zuckerberg, The Facebook, Inc. Motion Hearing set for 2/27/2008 09:30 AM. (Greer, Yvonne) (Filed on 2/22/2008) Text modified on 2/25/2008 conforming to posted document caption (bw, COURT STAFF). Modified on 4/30/2008,(counsel used incorrect event.) (cv, COURT STAFF). Modified on 5/2/2008 (cv, COURT STAFF).

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

Doc. 32

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SEAN A. LINCOLN (State Bar No. 136387) salinco [e-mail] 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 DOES 1-25, Defendants.

Case No. 5:07-CV-01389-RS PLAINTIFFS' MOTION TO SEAL EXHIBITS B-D TO THE DECLARATION OF YVONNE GREER SUBMITTING SUPPLEMENTAL EVIDENCE IN SUPPORT OF PLAINTIFFS' MOTION FOR PARTIAL SUMMARY JUDGMENT [DOC. 251]AND MOTION TO COMPEL COMPLIANCE BY PACIFIC NORTHWEST SOFTWARE AND WINSTON WILLIAMS [DOC. 271] Date: Time: Judge: February 27, 2008 9:30 A.M. Honorable Richard Seeborg

OHS West:260390718.1

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 B-D to the Declarat ion of Yvonne Greer Submitt ing Supplemental Evidence In Support of Plaintiffs' Motion For Partial Summary Judgment [Doc. 251] and Motion To Compel Co mpliance By Defendants Pacific Northwest Software And Winston Williams [Doc. 271] ("Greer Declaration"). The parties entered into, and the California Superior Court issued, a Stipulated Protective Order on January 23, 20061, 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. Exhibits B-D to the Greer Declaration are true and correct copies o f documents produced to Plaintiffs by Pacific Northwest Software in this action in response to a Rule 34 Request for Production of Documents, bearing production numbers PNS0598676-78, PNS0600661-63, and PNS0602084-86. These documents were designated "Confident ial" by Pacific Northwest Software pursuant to the Protective Order entered in this matter, and hence are subject to Local Civil Rule 79-5(d). Facebook takes no position regarding the propriety of the confidentiality designation of these documents.

Dated: February 22, 2008

Orrick, Herrington & Sutcliffe LLP /s/ Yvonne P. Greer /s/ Yvonne P. Greer Attorneys for Plaintiffs FACEBOOK, INC. AND MARK ZUCKERBERG

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The parties are in the process of drafting a new Stipulated Protective Order pursuant to this Court's instructions at the January 16, 2008 Case Management Conference.
OHS West:260390718.1

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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:260390718.1

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 February 22, 2008. Dated: February 22, 2008. Respect fully submitted, /s/ Yvonne P. Greer /s/ Yvonne P. Greer

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