Righthaven LLC v. Democratic Underground, LLC et al
Filing
86
DECLARATION of Clifford C. Webb In Support of Defendants' Request (Related Dkt. 85 ) to Unseal Exhibit A to Pulgram Declaration and Related Filings (Dkts. 74 , 79 re 73 MOTION to Seal 72 MOTION for Leave to File DEFENDANTS SUPPLEMENTAL MEMORANDUM ADDRESSING RECENTLY PRODUCED EVIDENCE RELATING TO PENDING MOTIONS, AND SUPPORTING DECLARATION OF LAURENCE PULGRAM -- MOTION to Seal 72 MOTION for Leave to File DEFENDANTS SUPPLEMENTAL MEMORANDUM ADDRESSING RECENTLY PRODUCED EVIDENCE RELATING TO PENDING MOTIONS, AND SUPPORTING DECLARATION OF LAURENCE PULGRAM -- ; filed by Defendants David Allen, Democratic Underground, LLC. (Webb, Cliff)
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LAURENCE F. PULGRAM (CA State Bar No. 115163) (pro hac vice) lpulgram@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, Plaintiff, v. 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.
CLIFFORD WEBB DECL. ISO DEFENDANTS' REQUEST TO UNSEAL CASE NO. 2:10-CV-01356-RLH (GWF)
Case No. 10-01356-RLH (GWF)
DECLARATION OF CLIFFORD C. WEBB IN SUPPORT OF DEFENDANTS' REQUEST TO UNSEAL EXHIBIT A TO PULGRAM DECLARATION AND RELATED FILINGS [DKT NOS. 74, 79]
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I, Clifford C. Webb, declare as follows: 1. I am an attorney licensed to practice law in the state of California and an associate
at Fenwick & West, LLP, counsel for Defendant/Cross-Complainant Democratic Underground, LLC and Defendant David Allen (hereinafter "Defendants") in this matter. I have personal knowledge of the facts stated in this declaration, and if called upon to do so, could and would competently testify thereto. 2. On March 3, 2011, counsel for Defendants first requested by e-mail that Stephens
Media and Righthaven agree to lift the "Confidential Attorneys' Eyes Only" designation on Exhibit A to the Pulgram Declaration, or to provide specific portions of that document for which the designation could be lifted. By March 9, 2011, neither Stephens Media nor Righthaven responded to that request. 3. On March 9, 2011, following this Court's March 8 Order, counsel for Defendants
again requested by e-mail that Stephens Media and Righthaven agree to lift the designation on Exhibit A and noted Defendants' willingness to attempt to stipulate to redaction of any appropriately limited portion identified by Stephens Media and Righthaven. 4. That same day, March 9th, counsel for Stephens Media and Righthaven refused to
lift the designation on Exhibit A. Since then, neither Righthaven nor Stephens Media have proposed redactions or sought a stipulated resolution from Defendants. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Executed on March 29, 2011, in San Francisco, California.
Dated: March 29, 2011
/s/ Clifford C. Webb CLIFFORD C. WEBB
CLIFFORD WEBB DECL. ISO DEFENDANTS' REQUEST TO UNSEAL
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CASE NO. 2:10-CV-01356-RLH (GWF)
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