Righthaven LLC v. Democratic Underground, LLC et al
Filing
167
MOTION to Seal Portions of Democratic Underground's Motion for Summary Judgment ("Consolidated Opposition") and Exhibits 9 and 12-17 of the Supporting Declaration of Kurt Opsahl by Defendants David Allen, Democratic Underground, LLC, Counter Claimant Democratic Underground, LLC. Motion ripe 10/24/2011. (Attachments: # 1 Proposed Order Granting Democratic Underground's Motion to File Documents Under Seal)(Johnson, Jennifer)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
LAURENCE F. PULGRAM (CA State Bar No. 115163) (pro hac vice)
lpulgram@fenwick.com
JENNIFER J. JOHNSON (CA State Bar No. 252897) (pro hac vice)
jjjohnson@fenwick.com
CLIFFORD C. WEBB (CA State Bar No. 260885) (pro hac vice)
cwebb@fenwick.com
FENWICK & WEST LLP
555 California Street, 12th Floor
San Francisco, California 94104
Telephone:
(415) 875-2300
Facsimile:
(415) 281-1350
KURT OPSAHL (CA State Bar No. 191303) (pro hac vice)
kurt@eff.org
CORYNNE MCSHERRY (CA State Bar No. 221504) (pro hac vice)
corynne@eff.org
ELECTRONIC FRONTIER FOUNDATION
454 Shotwell Street
San Francisco, California 94110
Telephone:
(415) 436-9333
Facsimile:
(415) 436-9993
CHAD BOWERS (NV State Bar No. 7283)
bowers@lawyer.com
CHAD A. BOWERS, LTD
3202 West Charleston Boulevard
Las Vegas, Nevada 89102
Telephone:
(702) 457-1001
Attorneys for Defendant and Counterclaimant
DEMOCRATIC UNDERGROUND, LLC, and
Defendant DAVID ALLEN
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEVADA
RIGHTHAVEN LLC, a Nevada limited liability company, Case No. 2:10-cv-01356-RLH (GWF)
Plaintiff,
v.
MOTION TO FILE DOCUMENTS
UNDER SEAL
DEMOCRATIC UNDERGROUND, LLC, a District of
Columbia limited-liability company; and DAVID ALLEN,
an individual,
Defendants.
DEMOCRATIC UNDERGROUND, LLC, a District of
Columbia limited-liability company,
Counterclaimant,
v.
RIGHTHAVEN LLC, a Nevada limited liability company,
and STEPHENS MEDIA LLC, a Nevada limited-liability
company,
Counterdefendants.
MOTION TO SEAL
CASE NO. 2:10-cv-01356-RLH (GWF)
1
2
REQUEST TO SUBMIT DOCUMENTS UNDER SEAL
Counterclaimant Democratic Underground, LLC (“Democratic Underground”) hereby
3
respectfully requests that the Court permit it to submit, under seal, portions of Democratic
4
Underground’s Motion for Summary Judgment (“Consolidated Opposition”), and Exhibits 9 and
5
12-17 of the Supporting Declaration of Kurt Opsahl (“Opsahl Decl.”).
6
All of these Exhibits were designated as “Confidential Attorneys Eyes Only” or
7
“Confidential” by Stephens Media under the Stipulated Protective Order entered by the Court on
8
February 14, 2011. Documents and information that have been designated by a party as
9
“Confidential Attorneys’ Eyes Only” can only be submitted to the Court under seal. See Dkt. 65,
10
¶ 12. While Democratic Underground does not maintain that Exhibits 9 and 12-17 are
11
appropriately designated under either the terms of the Stipulated Protective Order or applicable
12
law, and does not contend that the Exhibits should ultimately be maintained under seal,
13
Democratic Underground is required at this time to submit these Exhibits under seal. The same is
14
true for portions of Democratic Underground’s Consolidated Opposition which quote from and
15
summarize the contents of the Exhibits.
16
Accordingly, Democratic Underground respectfully requests that the Court allow it to
17
conditionally submit these documents under seal, until such time as Stephens Media provides a
18
basis for this Court to maintain them under seal.
19
Dated: October 24, 2011
FENWICK & WEST LLP
20
21
By: /s/ Jennifer J. Johnson
Jennifer J. Johnson
22
Attorneys for Defendant and Counterclaimant
DEMOCRATIC UNDERGROUND, LLC, and
Defendant DAVID ALLEN
23
24
25
26
27
28
MOTION TO SEAL
1
CASE NO. 2:10-cv-01356-RLH (GWF)
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?