Facebook, Inc. v. Studivz, Ltd et al

Filing 30

MOTION to Seal Document filed by Facebook, Inc.. (Attachments: # 1 Proposed Order)(Avalos, Julio) (Filed on 9/30/2008)

Facebook, Inc. v. Studivz, Ltd et al

Doc. 3

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GARY E. WEISS (State Bar No. 122962) [e-mail] m I. NEEL CHATTERJEE (State Bar No. 173985) [e-mail] JULIO C. AVALOS (STATE BAR NO. 255350) javalo [e-mail] ORRICK, HERRINGTON & SUTCLIFFE LLP 1000 Marsh Road Menlo Park, CA 94025 Telephone: [phone] Facsimile: 650-614-7401 WARRINGTON S. PARKER (State Bar No. 148003) [e-mail] m ORRICK, HERRINGTON & SUTCLIFFE LLP 405 Howard Street San Francisco, CA 94105 Telephone: [phone] Facsimile: 415-773-5759 Attorneys for Plaintiff FACEBOOK, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

FACEBOOK, INC., Plaintiff, v. STUDIVZ LTD., VERLAGSGRUPPE GEORG VON HOLTZBRINCK GmbH, HOLTZBRINCK NETWORKS GmbH, HOLTZBRINCK VENTURES GmbH AND DOES 1-25, Defendants.

Case No. 5:08-cv-03468 JF Assigned To: Honorable Judge Jeremy Fogel PLAINTIFF'S ADMINISTRATIVE MOTION TO SEAL PORTIONS OF: (1) DECLARATION OF JULIO C. AVALOS IN SUPPORT OF PLAINTIFF'S REPLY RE: PLAINTIFF'S MOTION FOR EXPEDITED PERSONAL JURISDICTION DISCOVERY AND EXHIBITS ATTACHED THERETO Date: Time: Room: Judge: October 14, 2008 10:00 a.m. Courtroom 2, 5th Floor Honorable Magistrate Judge Howard R. Lloyd, for Discovery Purposes

PLAINTIFF 'S ADMINISTRATIVE MOTION TO FILE UNDER SEAL CASE NO.: 5:08-CV-03468

Dockets.Justia.com

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Pursuant to Civil L.R. 7-11 and 79-5(c), Plaintiff Facebook, Inc. respectfully submits this administrative motion asking the Court to file under seal portions of the Declaration of Julio C. Avalos and Exhibits in Support Thereof ("Avalos Declaration"). The parties have not yet entered into a Protective Order in this matter, though they have scheduled a Rule 26 conference during which they will do so. Good cause exists for sealing certain narrowly tailored portions of the Avalos Declaration. In light of the high profile nature of this case and extensive media coverage that it has received, together with prior confidentiality agreements entered into between the parties that remain in force, Plaintiffs request that paragraph 22 of the Avalos Declaration, together with Exhibit I attached thereto, be filed under seal and redacted from the public record. The proposed redactions are narrowly tailored to cover only a single paragraph and accompanying exhibit which discuss confidential information. Dated: September 30, 2008 JULIO C. AVALOS Orrick, Herrington & Sutcliffe LLP

/s/ Julio C. Avalos /s/ JULIO C. AVALOS Attorneys for Plaintiff FACEBOOK, INC.

PLAINTIFF 'S ADMINISTRATIVE MOTION TO FILE UNDER SEAL CASE NO.: 5:08-CV-03468

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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 September 30, 2008. Dated: September 30, 2008. Respect fully submitted, /s/ Julio C. Avalos /s/ Julio C. Avalos

PLAINTIFF 'S ADMINISTRATIVE MOTION TO FILE UNDER SEAL CASE NO.: 5:08-CV-03468