Campbell et al v. Facebook Inc.

Filing 102

Administrative Motion to File Under Seal Portions of Facebook's Opposition to Plaintiffs' Motion to Withdraw Plaintiff David Shadpour Without Prejudice filed by Facebook Inc.. (Attachments: # 1 Declaration of Ashley Rogers in Support of Defendant Facebook, Inc.'s Administrative Motion to File Documents Under Seal, # 2 Exhibit A - Exhibit 5 to Decl. of Christopher Chorba - Unredacted and Filed Under Seal, # 3 Exhibit A - Exhibit 5 to Decl. of Christopher Chorba - Redacted and Filed Under Seal, # 4 Proposed Order Authorizing the Filing of Documents Under Seal)(Chorba, Christopher) (Filed on 7/27/2015)

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GIBSON, DUNN & CRUTCHER LLP
JOSHUA A. JESSEN, SBN 222831
[e-mail]
JEANA BISNAR MAUTE, SBN 290573
[e-mail]
ASHLEY M. ROGERS, SBN 286252
[e-mail]
1881 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]
GIBSON, DUNN & CRUTCHER LLP
GAIL E. LEES, SBN 90363
[e-mail]
CHRISTOPHER CHORBA, SBN 216692
[e-mail]
333 South Grand Avenue
Los Angeles, California 90071
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
FACEBOOK, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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MATTHEW CAMPBELL, MICHAEL
HURLEY, and DAVID SHADPOUR,
Plaintiffs,
v.
FACEBOOK, INC.,
Defendant.

Case No. C 13-05996 PJH
DEFENDANT FACEBOOK, INC.’S
ADMINISTRATIVE MOTION TO FILE
PORTIONS OF ITS OPPOSITION TO
PLAINTIFFS’ MOTION TO WITHDRAW
PLAINTIFF DAVID SHADPOUR
WITHOUT PREJUDICE UNDER SEAL
Date:
September 9, 2015
Time:
9:00 a.m.
Location: Courtroom 3, Third Floor
The Honorable Phyllis J. Hamilton

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Gibson, Dunn &
Crutcher LLP

DEFENDANT FACEBOOK, INC.’S ADMINISTRATIVE MOTION TO FILE PORTIONS OF ITS OPPOSITION TO PLAINTIFFS’
MOTION TO WITHDRAW PLAINTIFF DAVID SHADPOUR WITHOUT PREJUDICE UNDER SEAL
Case No. C 13-05996 PJH (MEJ)

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Pursuant to Civil Local Rules 7-11 and 79-5(b)-(d), and the Stipulated Protective Order that

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was entered by the Court on April 17, 2015 (Dkt. No. 76), Defendant Facebook, Inc. (“Facebook”)

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files this administrative motion to seal documents submitted in connection with its Opposition to

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Plaintiffs’ Motion to Withdraw Plaintiff David Shadpour Without Prejudice. Specifically, Facebook

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is lodging the following document under seal that Plaintiffs have designated as “Highly Confidential

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– Attorneys’ Eyes Only” in its entirety pursuant to the Stipulated Protective Order:

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Plaintiff David Shadpour’s Corrected Objections and Responses to Facebook’s First
Set of Interrogatories, which is attached as Exhibit 5 to the Declaration of Christopher
Chorba In Support of Facebook’s Opposition brief.

Plaintiffs have designated the entirety of Mr. Shadpour’s Interrogatory Responses as “Highly
Confidential – Attorneys’ Eyes Only” pursuant to the parties’ Stipulated Protective Order, and so
Facebook has redacted the entirety of those responses in its submission. Further, these responses do
contain Mr. Shadpour’s email addresses, usernames, and other personal information.
Accordingly, Facebook requests that the Court order that Shadpour’s Interrogatory Responses
be filed under seal.
Dated: July 27, 2015

Respectfully submitted,

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GIBSON, DUNN & CRUTCHER LLP

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By:

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/s/ Christopher Chorba
Christopher Chorba

Attorneys for Defendant FACEBOOK, INC.

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1

Gibson, Dunn &
Crutcher LLP

DEFENDANT FACEBOOK, INC.’S ADMINISTRATIVE MOTION TO FILE PORTIONS OF ITS OPPOSITION TO PLAINTIFFS’
MOTION TO WITHDRAW PLAINTIFF DAVID SHADPOUR WITHOUT PREJUDICE UNDER SEAL
Case No. C 13-05996 PJH (MEJ)