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

Filing 301

Assented to MOTION to Seal Plaintiffs' and Counsel's (Finnegan's) Response to Facebook's Motion for Limited Relief from Stay and to Enjoin Individual Plaintiffs and Their Counsel by Cameron Winklevoss, Tyler Winklevoss, Divya Narendra. (Attachments: # 1 Text of Proposed Order)(Hornick, John)

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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 THEFACEBOOK LLC, ) ) Defendants. CIVIL ACTION NO. 1:07-cv-10593 (DPW) Related Action 1:04-cv-11923 (DPW) ASSENTED MOTION TO SEAL PLAINTIFFS' AND COUNSEL'S (FINNEGAN'S) RESPONSE TO FACEBOOK'S MOTION FOR LIMITED RELIEF FROM STAY AND TO ENJOIN INDIVIDUAL PLAINTIFFS AND THEIR COUNSEL 1 Plaintiffs Cameron Winklevoss, Tyler Winklevoss, and Divya Narenda ("Plaintiffs") hereby move to file under seal the following document: PLAINTIFFS' AND COUNSEL'S (FINNEGAN'S) RESPONSE TO FACEBOOK'S MOTION FOR LIMITED RELIEF FROM STAY AND TO ENJOIN INDIVIDUAL PLAINTIFFS AND THEIR COUNSEL Plaintiffs respectfully request permission to file this document, due November 17, 2009, under seal because the motion to which it responds was filed under seal and the response contains information that Facebook may view as sensitive. In accordance with the Local Rules, Plaintiffs respectfully request that such response 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 Plaintiffs. 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 Counsel for Plaintiffs certify that pursuant to Local Rule 7.1, the parties have conferred regarding the motion to seal, and counsel for the Defendants Facebook, Inc., Mark Zuckerberg, Eduardo Saverin, Andrew McCollum, and Facebook, LLC consent to this motion. 2 DATED: November 13, 2009 /s/ John F. Hornick John F. Hornick (pro hac vice) Thomas H. Jenkins Margaret A. Esquenet (pro hac vice) FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. 901 New York Avenue N.W. Washington, DC 20001 Telephone: (202) 408-4000 Facsimile: (202) 408-4400 Daniel P. Tighe (BBO# 556583) Scott McConchie (BBO# 634127) GREISINGER, TIGHE, and MAFFEI, L.L.P. 176 Federal St. Boston, MA 02110 Telephone: (617) 452-9900 Facsimile: (617) 452-0900 dtighe@gtmllp.com smcconchie@gtmllp.com Attorneys for Plaintiffs 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) and paper copies will be sent to those indicated as non registered participants on November 13, 2009. /s/ John F. Hornick ____________ John F. Hornick 4

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