In Re FACEBOOK INTERNET TRACKING LITIGATION
Filing
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Administrative Motion to File Under Seal Stipulation and [Proposed] Order Requesting Limited Redaction of November 16, 2017 Hearing Transcript filed by Facebook Inc.. (Attachments: #1 Declaration of Kyle C. Wong in Support of Stipulation, #2 Exhibit A, #3 Exhibit B)(Brown, Matthew) (Filed on 12/13/2017)
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COOLEY LLP
MICHAEL G. RHODES (116127)
(rhodesmg@cooley.com)
MATTHEW D. BROWN (196972)
(brownmd@cooley.com)
KYLE C. WONG (224021)
(kwong@cooley.com))
101 California Street, 5th Floor
San Francisco, CA 94111-5800
Telephone:
(415) 693-2000
Facsimile:
(415) 693-2222
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Attorneys for Defendant FACEBOOK, INC.
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(Additional counsel on signature page)
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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In re: Facebook Internet Tracking Litigation
Case No. 12-md-02314 EJD
STIPULATION AND [PROPOSED] ORDER
REQUESTING LIMITED REDACTION OF
NOVEMBER 16, 2017 HEARING
TRANSCRIPT
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JUDGE:
COURTROOM:
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Hon. Edward J. Davila
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Plaintiffs Perrin Davis, Cynthia Quinn, Brian Lentz, and Matthew Vickery (collectively,
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“Plaintiffs”) and Defendant Facebook, Inc. (“Facebook”) (Plaintiffs and Facebook collectively,
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the “Parties”), by and through their respective counsel, hereby make a stipulated request for an
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order redacting one sentence in the Transcript from the November 16, 2017 Hearing on
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Facebook’s Motion to Dismiss (“Hearing Transcript”).
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WHEREAS during the November 16, 2017 hearing on Facebook’s Motion to Dismiss,
counsel for Plaintiffs made a reflecting certain discovery material designated Highly Confidential
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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO
1.
STIP. & [PROPOSED] ORDER RE
TRANSCRIPT REDACTION
CASE NO. 12-MD-02314 EJD
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by Facebook pursuant to the Stipulated Protective Order entered in this case (“Protective Order”)
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(ECF No. 75);
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WHEREAS the discovery material was quoted in and attached to Plaintiffs’ Second and
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Third Consolidated Amended Class Action Complaints, was addressed in two previous
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administrative motions to seal,1 and has twice been ordered sealed by the Court (ECF No. 150;
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ECF No. 170) (collectively “Sealing Orders”);
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WHEREAS the Parties’ counsel have conferred and agreed that a limited redaction of one
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sentence in the Hearing Transcript would be consistent with the Protective Order and this Court’s
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previous Sealing Orders;
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NOW, THEREFORE, the Parties hereby agree that redaction of the sentence contained in
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the Hearing Transcript at page 25, lines 20-21 (as indicated in Exhibits A and B to the
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Declaration of Kyle Wong filed concurrently herewith) is narrowly tailored to conform the
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transcript to the Protective Order and the Sealing Orders, and hereby make this stipulated request
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that the Court order this sentence to be redacted from any publicly available version of the
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Hearing Transcript.
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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO
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See Defendant Facebook’s Response to Plaintiffs’ Administrative Motion to File Under Seal
(ECF No. 94); Declaration of Natalie Naugle in Support of Defendant Facebook, Inc.’s Response
to Plaintiffs’ Administrative Motion to File Under Seal (ECF No. 94-1) at ¶¶ 2, 5; Defendant
Facebook, Inc.’s Response to Plaintiffs’ Administrative Motion to Seal (ECF No. 158);
Declaration of Natalie Naugle in Support of Defendant Facebook Inc.’s Response to Plaintiffs’
Administrative Motion to File Under Seal (ECF No. 158-2) at ¶¶ 2, 4.
2.
STIP. & [PROPOSED] ORDER RE
TRANSCRIPT REDACTION
CASE NO. 12-MD-02314 EJD
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Dated: December 13, 2017
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/s/ Matthew D. Brown
MATTHEW D. BROWN
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Attorneys for Defendant FACEBOOK, INC.
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COOLEY LLP
Dated: December 13, 2017
KAPLAN, FOX & KILSHEIMER LLP
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/s/ David A. Straite
DAVID A. STRAITE
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KAPLAN, FOX & KILSHEIMER LLP
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FREDERIC S. FOX (admitted pro hac vice)
DAVID A STRAITE (admitted pro hac vice)
850 Third Avenue
New York, NY 10022
Telephone:
(212) 687-1980
Facsimile:
(212) 687-7714
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LAWRENCE D. KING (206423)
MARIO M. CHOI (243409)
350 Sansome Street, 4th Floor
San Francisco, CA 94101
Telephone:
(415) 772-4700
Facsimile:
(415) 772-4707
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SILVERMAN, THOMPSON, SLUTKIN &
WHITE LLC
STEVEN G. GRYGIEL (admitted pro hac vice)
201 N. Charles St., #2600
Baltimore, MD 21201
Telephone:
(410) 385-2225
Facsimile:
(410) 547-2432
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Attorneys for Plaintiffs
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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO
3.
STIP. & [PROPOSED] ORDER RE
TRANSCRIPT REDACTION
CASE NO. 12-MD-02314 EJD
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[PROPOSED] ORDER
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The Court has considered the foregoing Stipulation by which the Parties request the
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limited redaction of one sentence contained in the November 16, 2017 Hearing Transcript at page
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25, lines 20-21 (as indicated in Exhibits A and B to the Declaration of Kyle Wong filed
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concurrently with the Stipulation). For the reasons set forth in the Stipulation and in this Court’s
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Orders of July 5, 2017 (ECF No. 150) and November 8, 2017 (ECF No. 170), it is hereby
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ORDERED that such sentence shall be redacted from any publicly available version of the
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Hearing Transcript, including, but not limited to, any electronic version of the transcript available
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to public terminal users at the courthouse or through the ECF or PACER systems. The
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unredacted version of the Hearing Transcript shall be placed under seal.
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Document
Nov. 16, 2017 Hearing
Transcript
Page/Line
Sentence contained on page 25, lines 20-21
Ruling
Granted
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DATED: ___________________
_________________________________________
The Honorable Edward J. Davila
UNITED STATES DISTRICT JUDGE
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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO
4.
STIP. & [PROPOSED] ORDER RE
TRANSCRIPT REDACTION
CASE NO. 12-MD-02314 EJD
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ATTESTATION
In accordance with Northern District of California Local Rule 5-1(i)(3), I hereby attest
that I have obtained concurrence in the filing of this Declaration from the signatories listed above.
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/s/ Matthew D. Brown
MATTHEW D. BROWN
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156952598
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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO
5.
STIP. & [PROPOSED] ORDER RE
TRANSCRIPT REDACTION
CASE NO. 12-MD-02314 EJD
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