The opinion of the court was delivered by: Hon. Lucy H. Koh United States District Judge
SECOND STIPULATION AND [PROPOSED] ORDER RE: FILING CERTAIN DOCUMENTS UNDER SEAL
Pursuant to Local Rule 7-12 and 79-5 and General Order 62, the parties stipulate and respectfully request this Court to permit the filing of certain exhibits under seal.
Plaintiffs have sued Doe Defendants alleging, among other things, Copyright Infringement and Trade Secret Misappropriation, arising from alleged posting on the internet of certain documents and/or links to certain documents, namely the Training Guide Phase One, the Continuation Manual, and the Yes! Teacher Notes (collectively, the "Manuals"), the Breath Water Sound Manual ("BWSM"), and a written description of Plaintiff's processes for teaching Sudarshan Kriya, Complaint, ¶¶ 39, 49, 68-70.
Defendants Doe/Klim and Doe/Skywalker have specially appeared and filed a Motion to Dismiss, a Special Motion to Strike, and a Motion to Quash. In support of these motions, Defendant Doe/Skywalker has filed a declaration, as to which he attached certain documents, some of which he proposed to file under seal. The documents he proposed to file under seal were: what he understands to be the "Sudarshan Kriya Notes" , Exhibit B, what he understands to be "Training Guide Phase 1," Exhibit C, what he understands to be "Yes Teacher Notes," Exhibit D and what he understands to be the BWSM, Exhibit E. Declaration of Doe/Skywalker, ¶ 9 (hereinafter "Proposed Sealed Exhibits").
The Proposed Sealed Exhibits were lodged with the Court on February 24, 2011.
Doe/Skywalker has proposed to file these documents under seal solely so as not to prejudice any rights that Plaintiff may have to assert Trade Secret rights or Copyrights as to such documents in this litigation.
Plaintiffs stipulate to and respectfully request the Court to order that Defendants be permitted to file the Proposed Sealed Exhibits under seal.
Nothing in this Stipulation should be construed as a waiver, admission or concession by either party regarding the factual, legal or evidentiary status of any of the Proposed Sealed Exhibits, or of any right any party or third party may have to seek to have such Exhibits unsealed at some future date.
Respectfully submitted, KRONENBERGER BURGOYNE LLP Jeffrey Rosenfeld Attorney for Plaintiff Art of Living Foundation Joshua Koltun Attorney for Doe/Klim and Doe/Skywalker PURSUANT TO STIPULATION, IT IS SO ORDERED 14 Dated: March May 1, 2011 7, 2011
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