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

Filing 223

Assented to MOTION to Seal Exhibit A to Sutton declaration in support of opposition to motion for sanctions by Dustin Moskovitz, Andrew McCollum, Christopher Hughes, Thefacebook LLC, Facebook, Inc., Mark Zuckerberg. (Attachments: #1 Text of Proposed Order)(Sutton, Theresa) Modified text on 12/12/2008 (Seelye, Terri).

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

Doc. 22

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-TO MOTION TO SEAL EXHIBIT A TO THE DECLARATION OF THERESA A. SUTTON IN SUPPORT OF FACEBOOK INC. AND MARK ZUCKERBERG'S OPPOSITION TO PLAINTIFFS' MOTION FOR SANCTION OF NON-DISMISSAL, OR IN THE ALTERNATIVE TO VACATE FINAL JUDGMENT PURSUANT TO F.R.C.P. 60

Dockets.Justia.com

Defendants Facebook, Inc. and Mark Zuckerberg, hereby move to file under seal pursuant to the Stipulated Protective Order entered between the parties in the related case, ConnectU v. Zuckerberg et al., Case No. 1:04-cv-11923-DPW, the following document: 1. EXHIBIT A TO THE DECLARATION OF THERESA A. SUTTON IN SUPPORT OF FACEBOOK INC. AND MARK ZUCKERBERG'S OPPOSITION TO PLAINTIFFS' MOTION FOR SANCTION OF NONDISMISSAL, OR IN THE ALTERNATIVE TO VACATE FINAL JUDGMENT PURSUANT TO F.R.C.P. 60

Facebook, Inc. and Mark Zuckerberg respect fully request permission to file this document under seal because it has been ordered to be placed under seal on June 20, 2008 by the Honorable Judge Ware in the Northern District of California. In accordance with the Local Rules, the Facebook Defendants respectfully request that this pleading and its supporting papers be impounded until 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.

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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: December 11, 2008 Respect fully submitted, /s/ Theresa A. Sutton /s/ Sean A. Lincoln* 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

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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 December 11, 2008. Dated: December 11, 2008 Respect fully submitted, /s/ Theresa A. Sutton /s/ Theresa A. Sutton
OHS West:260564694.1

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