Netquote Inc. v. Byrd

Filing 102

MOTION to Seal Document Reply Brief and Exhibits by Defendant, Inc.. (Attachments: # 1 Appendix LR 7.1 Certificate, # 2 Proposed Order (PDF Only) Proposed Order)(Isenberg, Ryan)

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Netquote Inc. v. Byrd Doc. 102 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 07-cv-00630-DME-MEH NETQUOTE INC, a Colorado corporation, Plaintiff, v. BRANDON BYRD, an internet user making use of the IP Addresses and, and MOSTCHOICE.COM, Inc., a Georgia corporation Defendants. ______________________________________________________________________________ MOTION TO FILE DOCUMENTS UNDER SEAL IN CONNECTION WITH DEFENDANT'S REPLY TO PLAINTIFF'S RESPONSE TO MOSTCHOICE'S MOTION FOR ADDITIONAL DISCOVERY ______________________________________________________________________________ COMES NOW,, Inc. and files this Motion to File Documents Under Seal in Connection with Defendants' Reply to Plaintiff's Response to Mostchoice's Motion for Additional Discovery and shows this Court the following: 1. The Court entered a protective order [Dkt. #74] on 8/23/07. 2. As part of the protective order, the parties have been granted the ability to designate certain documents as confidential and highly confidential, including documents produced and deposition transcripts. Page 1 of 3 3. Defendant, Inc. wishes to file certain documents, and portions of deposition transcripts that have been designated as confidential or highly confidential. Section 10 of the protective order requires documents that have been so designated to be filed under seal pursuant to LR 7.3. 4. Defendant's Reply Brief in this particular matter contains references to materials that have been designated confidential or highly confidential. Accordingly, defendant request permission to file both its Reply Brief and all exhibits thereto under seal. Dated this 13TH day of November, 2007. s/ Ryan Isenberg Ryan L. Isenberg, Esq. Isenberg & Hewitt, P.C. 7000 Peachtree Dunwoody Road Building 15, Suite 100 Atlanta, Georgia 30328 Telephone: 770-351-4400 Facsimile: 770-828-0100 (Fax) Email: Page 2 of 3 CERTIFICATE OF SERVICE I hereby certify that on this 13TH day of November, 2007, I served the foregoing Motion to File Documents under Seal by electronic delivery, as an attachment to an email, to the following counsel of record: David W. Stark Heather Carson Perkins Daniel D. Williams Theresa T. Tate FAEGRE & BENSON LLP 3200 Wells Fargo Center 1700 Lincoln Street Denver, Colorado 80203 s/ Ryan Isenberg Page 3 of 3

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