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

Filing 376

MOTION for leave to file under seal the Motion to Quash and Protective Order, Declaration of K. M. Lui-Kwan, and the Motion to change time of Deposition, and the Declaration of K. M. Lui-Kwan in support thereof. By Non-Parties filed by R. Gregory Roussel, Fenwick & West LLP. (Attachments: # 1 Proposed Order Granting Administrative Motion By Non-Parties R. Gregory Roussel and Fenwick & West LLP to Seal Documents)(Baker, Tyler) (Filed on 5/19/2008) Modified on 5/21/2008 (cv, COURT STAFF).

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

Doc. 37

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FENWICK & W EST LLP
A TTORNEYS AT L AW S AN F RANCISCO

TYLER BAKER (CSB NO. 65109) FENWICK & WEST LLP Silico n Valley Center 801 California Street Mountain View, CA 94041 Telephone: [phone] Facsimile: [phone] [e-mail] KALAMA M. LUI-KWAN (CSB NO. 242121) FENWICK & WEST LLP 555 California Street, 12th Floor San Francisco, CA 94104 Telephone: [phone] Facsimile: [phone] [e-mail] Attorneys for Non-Parties Fenwick & West LLP and R. Gregory Roussel UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION THE FACEBOOK, INC. and MARK ZUCKERBERG Plaint iffs, v. CONNECTU, INC. (formerly known as CONNECTU, LLC), PACIFIC NORTHWEST SOFTWARE, INC., WINSTON WILLIAMS, and WAYNE CHANG, Defendants. Case No. 5:07-CV-01389-JW ADMINISTRATIVE MOTION BY NON-PARTIES R. GREGORY ROUSSEL AND FENWICK & WEST LLP TO SEAL: (1) NOTICE OF MOTION AND MOTION TO QUASH AND FOR PROTECTIVE ORDER; MEMORANDUM OF POINTS AND AUTHORITIES (2) DECLARATION OF KALAMA M. LUI-KWAN IN SUPPORT OF MOTION TO QUASH AND FOR PROTECTIVE ORDER (3) [PROPOSED] ORDER GRANTING MOTION TO QUASH AND FOR PROTECTIVE ORDER (4) MISCELLANEOUS ADMINISTRATIVE REQUEST BY R. GREGORY ROUSSEL TO CHANGE TIME OF DEPOSITION PURSUANT TO CIVIL LOCAL RULE 7-11 (5) DECLARATION OF KALAMA M. LUI-KWAN IN SUPPORT OF MISCELLANEOUS ADMINISTRATIVE REQUEST BY R. GREGORY ROUSSEL TO CHANGE TIME OF DEPOSITION PURSUANT TO CIVIL LOCAL RULE 7-11 (6) [PROPOSED] ORDER GRANTING MISCELLANEOUS ADMINISTRATIVE REQUEST BY R. GREGORY ROUSSEL TO CHANGE TIME OF DEPOSITION -1-

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MOTION TO SEAL

CASE NO. 5:07-CV-01389-JW

Dockets.Justia.com

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FENWICK & W EST LLP
A TTORNEYS AT L AW S AN F RANCISCO

Pursuant to Civil L.R. 7-11 and 79-5(d), non-parties R. Gregory Roussel and Fenwick & West LLP (together, "Fenwick") respectfully submit this administrative motion asking the Court to file under seal: (1) Notice Of Motion And Motion To Quash And For Protective Order; Memorandum Of Points And Authorities; (2) Declaration Of Kalama M. Lui-Kwan In Support Of Motion To Quash And For Protective Order; (3) [Proposed] Order Granting Motion To Quash And For Protective Order; (4) Miscellaneous Administrative Request By R. Gregory Roussel To Change Time Of Deposition Pursuant To Civil Local Rule 7-11; (5) Declaration Of Kalama M. Lui-Kwan In Support Of Miscellaneous Administrative Request By R. Gregory Roussel To Change Time Of Deposition Pursuant To Civil Local Rule 7-11; And (6) [Proposed] Order Granting Miscellaneous Administrative Request By R. Gregory Roussel To Change Time Of Deposition ("Non-Party Filings"). The parties in this action entered into, and the California Superior Court issued, a Stipulated Protective Order on January 23, 2006, which prohibits either party fro m filing in the public record any documents that have been designated as "Confidential" or "Highly Confidential" pursuant to the Protective Order. Although Fenwick is not a party to this action, it has represented plaintiff Facebook, Inc. ("Facebook") in connection with certain matters related to Facebook's settlement of this action. The Non-Party Filings contain confidential information that is subject to the protection in the protective order. In light of the high profile nature of this case, and the parties' desire to keep the details of these documents private, Fenwick requests that this Administrative Request and its supporting papers remain sealed. The subject matter discussed in these papers includes commercially sensit ive and confidential information that, if released to the general public, will adversely affect the parties to this litigation. Dated: May 19, 2008 FENWICK & WEST LLP By: /s/ Tyler Baker Tyler Baker Attorneys for Non-Parties Fenwick & West LLP and R. Gregory Roussel
26246/00400/DOCS/1913103.1

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MOTION TO SEAL

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CASE NO. 5:07-CV-01389-JW(RS)