The opinion of the court was delivered by: Hon. Susan Illston United States District Court Judge
STIPULATED ADMINISTRATIVE MOTION TO FILE EXHIBITS UNDER SEAL WITH RESERVATION OF RIGHTS AND RELATED COUNTERCLAIMS
Pursuant to Civil Local Rules 7-11(a) and 79-5, the parties jointly move to file under seal exhibits F--H to the Reply Declaration of David M. Lacy Kusters In Support of Health Services Integration, Inc.'s ("HSI") Motion for Summary Judgment. Exhibits F--H were exhibits 8--10, respectively, to the deposition of Mr. Charles Freeman. The exhibits contain pricing information for Mr. Freeman's (d/b/a Innovative Engineering) products. In addition, Mr. Freeman's complete customer list could be derived from these documents. Mr. Freeman has designated these documents as "Highly Confidential-Attorneys' Eyes Only."
Golden Hour Data Systems, Inc. ("Golden Hour") stipulates to the filing of these exhibits under seal, but reserves its rights to object to the documents. Specifically, Golden Hour objects to the filing of any new evidence in support of HSI's motion on reply, and objects to HSI's reliance on any evidence not timely disclosed by HSI under Patent L.R. 3-3 and 3-4.
HSI believes that Golden Hour's objections are without merit.
Pursuant to the Stipulated Protective Order (Docket No. 38), which limits access to such designated materials, the parties respectfully request that the Court allow HSI to file portions of its filing under seal per Civil L.R. 79-5.
KNOBBE, MARTENS, OLSON & BEAR, LLP By: /s/ Frederick S. Berretta Attorneys for Plaintiff GOLDEN HOUR DATA SYSTEMS, INC. FENWICK & WEST LLP By: /s/ Heather Mewes Attorneys for Defendant HEALTH SERVICES INTEGRATION, INC.
HEATHER MEWES (CSB NO. 203690) firstname.lastname@example.org DAVID M. LACY KUSTERS (CSB NO. 241335) email@example.com FENWICK & WEST LLP 555 California Street, 12th floor San Francisco, CA 94104 Telephone: (415) 875-2300 Facsimile: (415) 281-1350 Attorneys for Defendant and Counterclaimant HEALTH SERVICES INTEGRATION, INC.
The Court having reviewed the parties' Stipulated Administrative Motion to File Exhibits Under Seal With Reservation of Rights, hereby, for good cause shown, orders that the exhibits F--H to the Reply Declaration of David M. Lacy Kusters In Support of Health Services Integration, Inc.'s Motion for Summary Judgment be filed under seal.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
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