Connectu, Inc. v. Facebook, Inc. et al

Filing 134

Assented to MOTION to Seal Memorandum In Support of Motion to Compel and Certain Exhibits to the Declaration of Monte Cooper by Dustin Moskovitz, Andrew McCollum, Thefacebook LLC, Facebook, Inc., Mark Zuckerberg. (Attachments: #1 Text of Proposed Order)(Sutton, Theresa)

Connectu, Inc. v. Facebook, Inc. et al

Doc. 134

Case 1:07-cv-10593-DPW

Document 134

Filed 10/24/2007

Page 1 of 4

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS CONNECTU, INC., CAMERON WINKLEVOSS, TYLER WINKLEVOSS, AND DIVYA NARENDRA, Plaint iff, v. FACEBOOK, INC., MARK ZUCKERBERG, EDUARDO SAVERIN, DUSTIN MOSKOVITZ, ANDREW MCCOLLUM, and FACEBOOK, LLC, Defendants.

Civil Action No. 1:07-CV-10593-DPW

ASSENTED-MOTION TO SEAL THE MEMORANDUM IN SUPPORT OF THE FACEBOOK DEFENDANTS' MOTION TO COMPEL PLAINTIFFS TO IMAGE AND SEARCH THEIR MEMORY DEVICES FOR SOURCE CODE, AND TO COMPLY WITH REQUESTS FOR PRODUCTION NOS. 1-2, 67-68 AND 117 AND EXHIBITS 3-4 AND 20-22 TO THE DECLARATION OF MONTE M. F. COOPER IN SUPPORT THEREOF

Motion To Seal Re Defendants' Motion To Compel
OHS West:260325601.1

Dockets.Justia.com

Case 1:07-cv-10593-DPW

Document 134

Filed 10/24/2007

Page 2 of 4

Defendants Facebook, Inc., Mark Zuckerberg, Dustin Moskovitz, Andrew McCollum, and TheFacebook, LLC (collectively, the "Facebook Defendants") hereby move to file under seal pursuant to the Stipulated Protective Order entered between the parties in the previous related case, ConnectU v. Zuckerberg et al., Case No. 1:04-cv-11923-DPW, the following documents and exhibit: 1. MEMORANDUM IN SUPPORT OF THE FACEBOOK DEFENDANTS' MOTION TO COMPEL PLAINTIFFS TO IMAGE AND SEARCH THEIR MEMORY DEVICES FOR SOURCE CODE, AND TO COMPLY WITH REQUESTS FOR PRODUCTION NOS. 1-2, 67-68 AND 117; AND EXHIBITS 3-4 AND 20-22 TO THE DECLARATION OF MONTE M. F. COOPER IN SUPPORT OF DEFENDANTS' MOTION TO COMPEL PLAINTIFFS TO IMAGE AND SEARCH THEIR MEMORY DEVICES FOR SOURCE CODE, AND TO COMPLY WITH REQUESTS FOR PRODUCTION NOS. 1-2, 67-68 AND 117.

2.

This motion is necessary to comply with the provisions of the Stipulated Protective Order. CERTIFICATION PURSUANT TO LOCAL RULE 7.1 Counsel for Defendants certifies that pursuant to Local Rule 7.1, the parties have conferred regarding the motions to seal, and counsel for the Plaintiffs ConnectU, Cameron Winklevoss, Tyler Winklevoss, and Divya Narendara and Eduardo Saverin consent to the motion. ///

-1Motion To Seal Re Defendants' Motion To Compel
OHS West:260325601.1

Case 1:07-cv-10593-DPW

Document 134

Filed 10/24/2007

Page 3 of 4

Dated: October 24, 2007.

Respect fully submitted, /s/ Theresa A. Sutton /s/ G. Hopkins Guy, III* I. Neel Chatterjee* Monte Cooper* Theresa A. Sutton* ORRICK, HERRINGTON & SUTCLIFFE LLP 1000 Marsh Road Menlo Park, California 94025 Telephone: [phone] Facsimile: [phone] [e-mail] m [e-mail] [e-mail] m [e-mail] Steven M. Bauer Jeremy P. Oczek PROSKAUER ROSE, LLP One International Plaza, 14th Floor Boston, MA 02110-2600 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] * Admitted Pro Hac Vice

-2Motion To Seal Re Defendants' Motion To Compel
OHS West:260325601.1

Case 1:07-cv-10593-DPW

Document 134

Filed 10/24/2007

Page 4 of 4

CERTIFICATE OF SERVICE I hereby certify that this document(s) filed through the ECF system will be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF) and paper copies will be sent to those indicated as non registered participants on October 24, 2007. Dated: October 24, 2007. Respect fully submitted, /s/ Theresa A. Sutton /s/ Theresa A. Sutton

-3Motion To Seal Re Defendants' Motion To Compel
OHS West:260325601.1