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

Filing 161

Assented to MOTION to Seal Documents by Dustin Moskovitz, Andrew McCollum, Thefacebook LLC, Facebook, Inc., Mark Zuckerberg.(Bauer, Steven)

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

Doc. 161

Case 1:07-cv-10593-DPW

Document 161

Filed 11/29/2007

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS
CONNECTU, INC., CAMERON WINKLEVOSS, TYLER WINKLEVOSS, AND DIVYA NARENDRA, Plaintiffs, v. FACEBOOK, INC., MARK ZUCKERBERG, EDUARDO SAVERIN, DUSTIN MOSKOVITZ, ANDREW MCCOLLUM, and FACEBOOK, LLC, Defendants. ASSENTED-TO MOTION TO FILE DOCUMENTS UNDER SEAL Defendants Facebook, Inc., Mark Zuckerberg, Dustin Moskovitz, Andrew McCollum, and Facebook, LLC ("the Facebook Defendants") hereby move to file under seal, pursuant to the Stipulated Protective Order entered by the Court in this case, the following documents: FACEBOOK DEFENDANTS' EMERGENCY REQUEST FOR A TEMPORARY RESTRAINING ORDER AGAINST PUBLICATION OR DISSEMINATION OF CONFIDENTIAL DOCUMENTS AND ORDER TO SHOW CAUSE WHY A PRELIMINARY INJUNCTION SHOULD NOT ISSUE; DECLARATION OF I. NEEL CHATTERJEE; PROPOSED ORDER; and EXHIBITS 1-10. Civil Action No. 1:07-CV-10593-DPW

The Facebook Defendants respectfully request permission to file this pleading and exhibits under seal because they contain information that has been designated by the parties as confidential under the Stipulated Protective Order entered in this case. In accordance with the Local Rules, the Facebook Defendants respectfully request that this pleading be impounded until

-1Dockets.Justia.com

Case 1:07-cv-10593-DPW

Document 161

Filed 11/29/2007

Page 2 of 3

the final resolution of this litigation between the parties, at which time it will be retrieved by counsel for the Facebook Defendants. WHEREFORE, it is respectfully requested that the Court grant this assented-to motion to file the above-described document under seal. Certification Pursuant to Local Rule 7.1 The undersigned counsel certifies that counsel for the parties have conferred in an attempt to resolve or narrow the issues presented by this motion, and that counsel for plaintiff ConnectU LLC has assented to the relief requested by this motion, pursuant to an agreement between the parties.

Dated: November 29, 2007

Respectfully submitted, /s/ Steven M. Bauer Steven M. Bauer Jeremy P. Oczek PROSKAUER ROSE, LLP One International Plaza, 22nd Floor Boston, MA 02110-2600 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] 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] [e-mail] [e-mail] [e-mail] * Admitted Pro Hac Vice

-2-

Case 1:07-cv-10593-DPW

Document 161

Filed 11/29/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that this document filed through the ECF system will be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF) on November 29, 2007.

Dated: November 29, 2007

/s/ Steven M. Bauer Steven M. Bauer PROSKAUER ROSE, LLP One International Plaza, 22nd Floor Boston, MA 02110-2600

-3-