Mahamedi et al v. Paradice et al

Filing 121

ORDER GRANTING 94 STIPULATION RE: ADMINISTRATIVE MOTION TO SEAL. Signed by Judge Edward J. Davila on 6/30/2017. (ejdlc2S, COURT STAFF) (Filed on 6/30/2017)

Case 5:16-cv-02805-EJD Document 94 Filed 04/04/17 Page 1 of 4

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Perry J. Narancic, SBN 206820
LEXANALYTICA, PC
2225 E. Bayshore Road, Suite 200
Palo Alto, CA 94303
www.lexanalytica.com
[e-mail]
Tel: [phone]
Attorneys for Plaintiffs
ZURVAN MAHAMEDI and MAHAMEDI IP
LAW, LLP

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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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CASE NO. 16-cv-2805 EJD

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ZURVAN MAHAMEDI and MAHAMEDI IP
LAW, LLP,
Plaintiffs,

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Courtroom 4
Judge Edward J. Davila

v.

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STIPULATION RE:
ADMINISTRATIVE MOTION TO
SEAL (Dkt. No. 89)

WILLIAM PARADICE,

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Defendant.

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Pursuant to Civ. L.R. 79-5(e), the parties in this case, Plaintiffs Zurvan Mahamedi and

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Mahamedi IP Law, LLP (together, the “Plaintiffs”), and Defendant William Paradice

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(“Paradice”) stipulate as follows:

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WHEREAS Plaintiffs filed an administrative motion at Dkt. No. 84 seeking a clarification

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of the Court’s order at Dkt. No. 69;
WHEREAS Paradice filed an opposition to Plaintiffs’ clarification motion, at Dkt. No.

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90;
WHEREAS Paradice’s opposition included a motion to file certain documents under seal
- 1Mahamedi v. Paradice
Case No. 16-cv-2805 EJD

Stipulation re: Administrative Motion to Seal (Dkt. No. 89)

Case 5:16-cv-02805-EJD Document 94 Filed 04/04/17 Page 2 of 4

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- specifically: (a) a document referred to by Plaintiffs as the “RTU Email”, and attached as

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Exhibit B to the Declaration of Brian Mitchell (filed under seal at Dkt. No. 90-3), and (b) a second

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document consisting of an email dated March 6, 2016, and attached as Exhibit C to the

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Declaration of Brian Mitchell (filed under seal at Dkt. No. 90-4) (together, the “Subject

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Documents”);

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WHEREAS the Subject Documents were designated as “confidential” by Plaintiffs;

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WHEREAS Plaintiffs originally filed the March 6, 2016 email as an exhibit to the

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Declaration of Zurvan Mahamedi in Support of Plaintiffs’ Motion for Clarification (at Dkt. No. 87-

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2) with significant redactions;

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WHEREAS the parties have resolved a dispute regarding the appropriate amount of redaction
for the March 6, 2016 email;

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WHEREAS the parties agree that the redactions set forth in the accompanying Exhibit A

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strike a compromise between the parties for the purpose of fairly prosecuting and defending the case,

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while respecting the public interest in transparency;

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NOW THEREFORE, the parties respectfully request that the Court seal Dkt. No. 90-4, and

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approve the redactions set forth in the accompanying Exhibit A as the publicly available version of

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Dkt. No. 90-4. In the event that the Court is inclined not to so seal the Dkt. No. 90-4, the parties

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request that the Court allow seven days after such an order to allow the clients that may be affected

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by such an order to file papers, if any, in support of sealing the Subject Documents.

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IT IS SO STIPULATED.

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- 2Mahamedi v. Paradice
Case No. 16-cv-2805 EJD

Stipulation re: Administrative Motion to Seal (Dkt. No. 89)

Case 5:16-cv-02805-EJD Document 94 Filed 04/04/17 Page 3 of 4

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Dated: April 4, 2017

Respectfully submitted,

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LEXANALYTICA, PC
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By /s/ Perry J. Narancic
LEXANALYTICA, PC
2225 E. Bayshore Road, Suite 200
Palo Alto, CA 94303
www.lexanalytica.com
[e-mail]
Tel: [phone]

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Attorneys for Plaintiffs
ZURVAN MAHAMEDI and MAHAMEDI
IP LAW, LLP

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/s/ Brian Mitchell
Mitchell + Company
4 Embarcadero Center, Suite 1400
San Francisco, CA 94111
Tel: [phone]

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Attorney for Defendant
WILLIAM PARADICE

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Attestation
Pursuant to Civil L.R. 5-1(i)(3), I attest that concurrence in the filing of this document has

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been obtained from each of the other signatories to this document.

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Dated: April 4, 2017

By: /s/ Perry J. Narancic

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- 3Mahamedi v. Paradice
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Stipulation re: Administrative Motion to Seal (Dkt. No. 89)

Case 5:16-cv-02805-EJD Document 94 Filed 04/04/17 Page 4 of 4

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[PROPOSED] ORDER

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GOOD CAUSE appearing therefore, and having considered the stipulation of the parties and
the Declaration of Zurvan Mahamedi in Support of the Administrative Motion to Seal at Dkt. No.
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87, the Administrative Motion to Seal is GRANTED, and Paradice shall file, as the public version
of Dkt. No. 90-4, the redacted document filed as Exhibit A to the parties’ stipulation.

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OR

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GOOD CAUSE appearing therefore, and having considered the stipulation of the parties and
the Declaration of Zurvan Mahamedi in Support of the Administrative Motion to Seal at Dkt. No.
87, the Administrative Motion to Seal is DENIED. This order shall be stayed for 7 days following
entry hereof, to allow the clients that may be affected by this order to file supplemental papers, if
any, in support of reconsideration of this order.

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IT IS SO ORDERED.
DATE: June 30, 2017
By:

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Hon. Edward J. Davila
United States District Judge

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.

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- 4Mahamedi v. Paradice
Case No. 16-cv-2805 EJD

Stipulation re: Administrative Motion to Seal (Dkt. No. 89)