Mou v. City of San Jose et al

Filing 57

BILL OF COSTS and Declaration of Robert Burchfiel In Support of Defendant's Bill of Cost with Exhibits by City of San Jose. (Burchfiel, Robert) (Filed on 10/8/2009)

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Mou v. City of San Jose et al Doc. 57 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 Scott R. Mosko (State Bar No. 106070) scott.mosko@finnegan.com FINNEGAN HENDERSON, FARABOW, GARRETT & DUNNER, LLP Stanford Research Park 3300 Hillview Ave. Palo Alto, CA Telephone: (650) 849-6600 Facsimile: (650) 849-6666 Attorneys for Defendants Winston Williams and Pacific Northwest Software, Inc. *E-FILED 4/26/07* UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION THE FACEBOOK, INC., Plaintiffs, v. CONNECTU LLC, (now known as CONNECTU INC.) PACIFIC NORTHWEST SOFTWARE, WINSTON WILLIAMS, AND DOES 1-25, Defendants. CASE NO. 5:07-CV-01389-RS DEFENDANTS' PACIFIC NORTHWEST SOFTWARE AND WINSTON WILLIAMS ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL; DECLARATION OF SCOTT R. MOSKO; [PROPOSED] ORDER Date: May 16, 2007 Time: 9:30 a.m. Courtroom: 4 Mag. Judge: Hon. Richard Seeborg Doc. No. 461765 DEFENDANT'S ADMINISTRATIVE MOTION AND [PROPOSED] ORDER TO FILE DOCUMENTS UNDER SEAL Case No. 5;07-CV-01389-RS) Dockets.Justia.com 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 Doc. No. 461765 ADMINISTRATIVE MOTION FOR FILING UNDER SEAL Pursuant to Civil Local Rules 7-11 and 79-5(c), Defendants respectfully request leave of Court to file under seal the following documents: DEFENDANTS' PACIFIC NORTHWEST SOFTWARE AND WINSTON WILLIAMS OPPOSITION TO FACEBOOK, INC.'S MOTION FOR EXPEDITED DISCOVERY RE: PERSONAL JURISDICTION (HIGHLIGHTED VERSION FOR FILING UNDER SEAL) EXHIBITS D AND E TO THE DECLARATION OF SCOTT R. MOSKO IN SUPPORT OF DEFENDANTS' PACIFIC NORTHWEST SOFTWARE AND WINSTON WILLIAMS OPPOSITION TO FACEBOOK, INC.'S MOTION FOR EXPEDITED DISCOVERY RE: PERSONAL JURISDICTION (FILED UNDER SEAL IN THEIR ENTIRETIES) Each of the above-listed documents contain information that has been designated "Confidential" under the protective order, Defendants are filing this motion as required by Civ. L.R. 79-5(d). As required by Civil Local Rule 79-5(c), Defendants are lodging with the Clerk copies of these documents which the confidential information has been highlighted (for filing under seal) and redacted (for public filing). SUPPORTING DECLARATION OF SCOTT R. MOSKO I, Scott R. Mosko, declare as follows: 1. I am an attorney admitted to practice in the State of California and the United States District Court for the Northern District of California, and a partner of Finnegan, Henderson, Farabow, Garrett & Dunner, L.L.P., attorneys of record for Defendants Pacific Northwest Software and Winston Williams. The matters referred to in this declaration are based on my personal knowledge and if called as a witness I could, and would, testify competently to those matters. 2. The representations made above in this Administrative Motion are true and correct to the best of my knowledge and belief. 1 DEFENDANT'S ADMINISTRATIVE MOTION AND [PROPOSED] ORDER TO FILE DOCUMENTS UNDER SEAL Case No. 5:07-CV-01389-RS 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 I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct and that this declaration was executed on April 25, 2007, in Palo Alto, California. By: Scott R. Mosko /s/ [PROPOSED] ORDER Upon good cause shown, IT IS HEREBY ORDERED that the following documents shall be received and filed under seal in their entireties by the Clerk: 1. Exhibits D and E to the Declaration of Scott R. Mosko in Support of Defendants' Opposition to Plaintiffs' Motion Facebook, Inc.'s Motion for Expedited Discovery Re: Personal Jurisdiction. IT IS FURTHER ORDERED that the highlighted version of the following document be filed under seal by the Clerk: 2. Defendants Opposition to Plaintiffs' Motion Facebook, Inc.'s Motion for Expedited Discovery Re: Personal Jurisdiction. April 26 Dated: ____________, 2007 __________________________ Honorable Richard Seeborg Doc. No. 461765 2 DEFENDANT'S ADMINISTRATIVE MOTION AND [PROPOSED] ORDER TO FILE DOCUMENTS UNDER SEAL Case No. 5:07-CV-01389-RS

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