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

Filing 286

MOTION to Seal Facebook's Motion to Enjoin Iand Exhibits 8, 9, 10, 12, 13 and 21 to Cooper Declaration, MOTION to Seal Document ( Responses due by 11/17/2009) by Facebook, Inc.. (Attachments: #1 Text of Proposed Order)(Sutton, Theresa)

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

Doc. 28

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 FACEBOOK'S MOTION TO ENJOIN INDIVIDUAL PLAINTIFFS AND THEIR COUNSEL AND EXHIBITS 8, 9, 10, 12, 13 AND 21 TO THE DECLARATION OF MONTE M. F. COOPER IN SUPPORT THEREOF

Dockets.Justia.com

Defendant Facebook, Inc., hereby moves 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 documents: 1. 2. 3. 4. 5. 6. 7. FACEBOOK'S MOTION TO ENJOIN INDIVIDUAL PLAINTIFFS AND THEIR COUNSEL; EXHIBIT 8 TO THE DECLARATION OF MONTE M. F. COOPER IN SUPPORT THEREOF; EXHIBIT 9 TO THE DECLARATION OF MONTE M. F. COOPER IN SUPPORT THEREOF;. EXHIBIT 10 TO THE DECLARATION OF MONTE M. F. COOPER IN SUPPORT THEREOF; EXHIBIT 12 TO THE DECLARATION OF MONTE M. F. COOPER IN SUPPORT THEREOF; EXHIBIT 13 TO THE DECLARATION OF MONTE M. F. COOPER IN SUPPORT THEREOF; and EXHIBIT 21 TO THE DECLARATION OF MONTE M. F. COOPER IN SUPPORT THEREOF.

Facebook respectfully request permission to file these documents under seal because they contain information that has been designated by Plaintiffs as confidential under the Second Stipulated Protective Order, or that are similarly protected from disclosure under a Protective Order entered in a pending arbitration to which the Plaintiffs are a party. In accordance with the Local Rules, Facebook respectfully requests 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 Facebook. 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 has assented to the relief requested by this motion, pursuant to an agreement between the parties. Dated: November 3, 2009. Respect fully submitted, /s/ Theresa A. Sutton /s/ 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] 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 November 3, 2009. Dated: November 3, 2009 Respect fully submitted, /s/ Theresa A. Sutton /s/ Theresa A. Sutton
OHS West:260755245.1

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