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The Facebook, Inc. v. Connectu, LLC et al - 53

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									The Facebook, Inc. v. Connectu, LLC et al                                                                                 Doc. 53
                     Case 5:07-cv-01389-RS         Document 53   Filed 04/25/2007         Page 1 of 3



         1   Scott R. Mosko (State Bar No. 106070)
             scott.mosko@finnegan.com
         2   FINNEGAN HENDERSON, FARABOW,
              GARRETT & DUNNER, LLP
         3   Stanford Research Park
             3300 Hillview Ave.
         4   Palo Alto, CA
             Telephone: (650) 849-6600
         5   Facsimile: (650) 849-6666
         6   Attorneys for Defendants
             Winston Williams and Pacific Northwest
         7   Software, Inc.
         8

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       10                                    UNITED STATES DISTRICT COURT
       11                                   NORTHERN DISTRICT OF CALIFORNIA
       12                                          SAN JOSE DIVISION
       13
             THE FACEBOOK, INC.,                                   CASE NO. 5:07-CV-01389-RS
       14
                                     Plaintiffs,                   DEFENDANTS’ PACIFIC
       15                                                          NORTHWEST SOFTWARE AND
                               v.                                  WINSTON WILLIAMS
       16                                                          ADMINISTRATIVE MOTION TO
             CONNECTU LLC, (now known as CONNECTU                  FILE DOCUMENTS UNDER SEAL;
       17    INC.) PACIFIC NORTHWEST SOFTWARE,                     DECLARATION OF SCOTT R.
             WINSTON WILLIAMS, AND DOES 1-25,                      MOSKO; [PROPOSED] ORDER
       18
                                     Defendants.                   Date:       May 16, 2007
       19                                                          Time:       9:30 a.m.
                                                                   Courtroom: 4
       20                                                          Mag. Judge: Hon. Richard Seeborg
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                                                                 DEFENDANT’S ADMINISTRATIVE MOTION AND [PROPOSED]
             Doc. No. 461765                                                  ORDER TO FILE DOCUMENTS UNDER SEAL
                                                                                             Case No. 5;07-CV-01389-RS)
                                                                                                           Dockets.Justia.com
             Case 5:07-cv-01389-RS           Document 53        Filed 04/25/2007         Page 2 of 3



 1                        ADMINISTRATIVE MOTION FOR FILING UNDER SEAL
 2            Pursuant to Civil Local Rules 7-11 and 79-5(c), Defendants respectfully request leave of Court

 3   to file under seal the following documents:

 4                 •   DEFENDANTS’ PACIFIC NORTHWEST SOFTWARE AND WINSTON
 5                     WILLIAMS OPPOSITION TO FACEBOOK, INC.’S MOTION FOR
 6                     EXPEDITED DISCOVERY RE: PERSONAL JURISDICTION (HIGHLIGHTED
 7                     VERSION FOR FILING UNDER SEAL)
 8                 •   EXHIBITS D AND E TO THE DECLARATION OF SCOTT R. MOSKO IN
 9                     SUPPORT OF DEFENDANTS’ PACIFIC NORTHWEST SOFTWARE AND
10                     WINSTON WILLIAMS OPPOSITION TO FACEBOOK, INC.’S MOTION FOR
11                     EXPEDITED DISCOVERY RE: PERSONAL JURISDICTION (FILED UNDER
12                     SEAL IN THEIR ENTIRETIES)
13            Each of the above-listed documents contain information that has been designated

14   “Confidential” under the protective order, Defendants are filing this motion as required by Civ. L.R.

15   79-5(d). As required by Civil Local Rule 79-5(c), Defendants are lodging with the Clerk copies of

16   these documents which the confidential information has been highlighted (for filing under seal) and

17   redacted (for public filing).

18                          SUPPORTING DECLARATION OF SCOTT R. MOSKO
19   I, Scott R. Mosko, declare as follows:

20            1.       I am an attorney admitted to practice in the State of California and the United States

21   District Court for the Northern District of California, and a partner of Finnegan, Henderson, Farabow,

22   Garrett & Dunner, L.L.P., attorneys of record for Defendants Pacific Northwest Software and Winston

23   Williams. The matters referred to in this declaration are based on my personal knowledge and if

24   called as a witness I could, and would, testify competently to those matters.

25            2.       The representations made above in this Administrative Motion are true and correct to

26   the best of my knowledge and belief.

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                                                               DEFENDANT’S ADMINISTRATIVE MOTION AND [PROPOSED]
     Doc. No. 461765                                      1                 ORDER TO FILE DOCUMENTS UNDER SEAL
                                                                                           Case No. 5:07-CV-01389-RS
             Case 5:07-cv-01389-RS          Document 53          Filed 04/25/2007         Page 3 of 3



 1            I declare under penalty of perjury under the laws of the United States of America that the

 2   foregoing is true and correct and that this declaration was executed on April 25, 2007, in Palo Alto,

 3   California.

 4                                                   By:                        /s/
                                                               Scott R. Mosko
 5

 6

 7                                            [PROPOSED] ORDER
 8            Upon good cause shown, IT IS HEREBY ORDERED that the following documents shall be
 9   received and filed under seal in their entireties by the Clerk:
10            1.       Exhibits D and E to the Declaration of Scott R. Mosko in Support of Defendants’
11            Opposition to Plaintiffs’ Motion Facebook, Inc.’s Motion for Expedited Discovery Re:
12            Personal Jurisdiction.
13            IT IS FURTHER ORDERED that the highlighted version of the following document be filed
14   under seal by the Clerk:
15            2.       Defendants Opposition to Plaintiffs’ Motion Facebook, Inc.’s Motion for Expedited
16            Discovery Re: Personal Jurisdiction.
17

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19   Dated: ____________, 2007                                         __________________________
                                                                       Honorable Richard Seeborg
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                                                                DEFENDANT’S ADMINISTRATIVE MOTION AND [PROPOSED]
     Doc. No. 461765                                       2                 ORDER TO FILE DOCUMENTS UNDER SEAL
                                                                                            Case No. 5:07-CV-01389-RS

								
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