Interserve, Inc. et al v. Fusion Garage PTE. LTD

Filing 76

MOTION to Seal Document 72 Memorandum in Opposition, 73 Declaration in Support, filed by Fusion Garage PTE. LTD. (Attachments: # 1 Proposed Order)(Doolittle, Patrick) (Filed on 4/26/2010)

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1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Claude M. Stern (Bar No. 96737) 2 claudestern@quinnemanuel.com Patrick Doolittle (Bar No. 203659) 3 patrickdoolittle@quinnemanuel.com 50 California Street, 22nd Floor 4 San Francisco, California 94111 Telephone: (415) 875-6600 5 Facsimile: (415) 875-6700 6 Attorneys for Defendant Fusion Garage PTE Ltd. 7 8 9 10 11 INTERSERVE, INC. dba TECHCRUNCH, a Delaware corporation, and CRUNCHPAD, 12 INC., a Delaware corporation, 13 14 vs. Plaintiffs, CASE NO. C 09-cv-5812 RS FUSION GARAGE'S ADMINISTRATIVE MOTION TO FILE UNDER SEAL (Civil Local Rule 79-5) UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 15 FUSION GARAGE PTE LTD., a Singapore company, 16 Defendant. 17 18 19 20 21 22 23 24 25 26 27 28 04049.51632/3468973.1 Case No. C 09-cv-5812 RS MOTION TO FILE UNDER SEAL 1 Pursuant to Civil Local Rule 79-5, Defendant Fusion Garage PTE, Ltd. hereby submits this 2 administrative motion for an order to provisionally file under seal the following documents 3 attached to the Declaration of Patrick C. Doolittle in Support of Fusion Garage's Opposition to 4 Plaintiffs' Motion for Preliminary Injunction: 5 As set forth in the Doolittle Declaration, Exhibit A comprises excerpts from the deposition 6 transcript of TechCrunch's 30(b)(6) representative, Michael Arrington. TechCrunch provisionally 7 designated the entire deposition transcript as highly Confidential-Attorney's Eyes Only, although 8 Fusion Garage disagrees with this confidential designation and has filed a still-pending motion to 9 remove the confidentiality designation (Dkt. 66). 10 As set forth in the Doolittle Declaration, Exhibit B and Exhibit C comprise email 11 exchanges between TechCrunch personnel Michael Arrington and Nik Cubrilovic, which 12 TechCrunch designated as Confidential. 13 Fusion Garage is filing the present motion to maintain Exhibits A, B, and C in confidence 14 pursuant to the Stipulated Protective Order. 15 Furthermore, Fusion Garage's Opposition Brief to Plaintiffs' Motion for Preliminary 16 Injunction quotes and cites certain portions of Exhibits A, B, and C from the Doolittle Declaration. 17 Accordingly, Fusion Garage respectfully requests to file its Opposition Brief under seal as well, 18 and will file a redacted version of the Opposition Brief that omits citations and quotations to 19 Exhibits A, B, and C. 20 21 22 23 24 25 26 27 28 04049.51632/3468973.1 DATED: April 26, 2010 QUINN EMANUEL URQUHART & SULLIVAN, LLP By /s/ Patrick Doolittle Patrick C. Doolittle Attorneys for Defendant Fusion Garage PTE Ltd, MOTION TO FILE UNDER SEAL -1- Case No. C 09-cv-5812 RS

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