Louis Vuitton Malletier, S.A. v. Akanoc Solutions, Inc. et al

Filing 139

MOTION to Seal Exhibit A to Plaintiff's 137 Notice and Motion for Modification of Order for Inspection and Sanctions; CORRECTION OF DOCKET # 138 filed by Louis Vuitton Malletier, S.A.. (Attachments: # 1 Proposed Order)(Coombs, J.) (Filed on 4/15/2009) Modified on 4/16/2009,(counsel failed to properly link to motion.) (cv, COURT STAFF).

Download PDF
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 J. Andrew Coombs (SBN 123881) Annie S. Wang (SBN 243027) J. Andrew Coombs, A Prof. Corp. 517 E. Wilson Ave., Suite 202 Glendale, California 91206 Telephone: (818) 500-3200 Facsimile: (818) 500-3201 andy@coombspc.com annie@coombspc.com Attorneys for Plaintiff Louis Vuitton Malletier, S.A. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA (SAN JOSE) Louis Vuitton Malletier, S.A., Plaintiff, v. Akanoc Solutions, Inc., et al. Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. CV 07-3952 JW PLAINTIFF'S ADMINISTRATIVE MOTION TO FILE UNDER SEAL EXHIBIT A TO PLAINTIFF'S NOTICE AND MOTION FOR MODIFICATION OF ORDER FOR INSPECTION AND SANCTIONS; DECLARATION OF J. ANDREW COOMBS IN SUPPORT Local Rule 79-5(c) Plaintiff Louis Vuitton Malletier, S.A. ("Plaintiff") hereby does move the Court, pursuant to the Northern District Local Rule 79-5(c), for an order requiring that Exhibit A ("Exhibit") to Plaintiff's Notice and Motion for Modification of Order for Inspection and Sanctions ("Motion") be filed under seal, until such time as the court orders otherwise. Good cause exists for Plaintiff's request pursuant to paragraph 5 of the Court's March 10, 2009, Order re Discovery Protocol, as the documents may be deemed as produced during the inspection and covered under the protective order. Thus, Plaintiff seeks an order from the Court to have the Exhibit filed under seal without waiving any of its rights to challenge any designation made by Defendants. This order is sought Louis Vuitton Malletier, S.A. v. Akanoc Solutions, et al.: Administrative Motion to File Under Seal -1- 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 the Court's equitable powers. See, e.g., Crystal Grower's Corp. v. Dobbins, 616 F.2d 458, 461 (10th Cir. 1980). Dated: April 14, 2009 J. Andrew Coombs, A Professional Corp. By: __/s/ J. Andrew Coombs___________ J. Andrew Coombs Annie S. Wang Attorneys for Plaintiff Louis Vuitton Malletier, S.A. Louis Vuitton Malletier, S.A. v. Akanoc Solutions, et al.: Administrative Motion to File Under Seal -2- 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 DECLARATION OF J. ANDREW COOMBS I, J. ANDREW COOMBS, declare as follows: 1. I am a member of the Bar of this Court and an officer of J. Andrew Coombs, A Professional Corporation, counsel of record for Plaintiff Louis Vuitton Malletier, S.A. ("Plaintiff") in this Action. Except as otherwise expressly stated to the contrary, I have personal knowledge of the following facts and, if called as a witness, I could and would competently testify thereto. 2. Paragraph 5 of the Court's March 10, 2009, Order re Discovery Protocol, provides for coverage under the protective order of "documents produced" and each party to have 20 days to designate material as confidential. I am informed and believe that though the document may not be considered part of the "production" from the inspection and is arguably not able to be designated as "Confidential" by Defendants, in an abundance of caution, the photographs taken of Defendants' computer screens from the date of the inspection are nevertheless being requested to be filed under seal. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this 14th day of April, 2009, at Glendale, California. _____/s/ J. Andrew Coombs________ J. ANDREW COOMBS Louis Vuitton Malletier, S.A. v. Akanoc Solutions, et al.: Administrative Motion to File Under Seal -3-

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?