UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION
June 13, 2011
FACEBOOK, INC., PLAINTIFF,
POWER VENTURES, INC. A CAYMAN ISLAND CORPORATION;
STEVE VACHANI, AN INDIVIDUAL; DOE 1, D/B/A POWER.COM, DOES 2-25, INCLUSIVE,
The opinion of the court was delivered by: Hon. Judge James Ware
BURSOR & FISHER, P.A. L. Timothy Fisher (State Bar No. 191626) 2121 North California Boulevard, Suite 1010 Walnut Creek, CA 94596 Telephone: (925) 482-1515 Facsimile: (925) 407-2700 E-Mail: email@example.com BURSOR & FISHER, P.A. Scott A. Bursor (State Bar No. th 276006) 369 Lexington Avenue, 10 Floor New York, NY 10017 Telephone: (212) 989-9113 Facsimile: (212) 989-9163 E-Mail: firstname.lastname@example.org Attorneys for Defendants
STIPULATION TO WITHDRAW EXHIBIT C TO FISHER DECLARATION (DKT. NO. 98)
and Power.com (collectively "Defendants"), by and through their respective counsel, hereby 4 stipulate and agree as follows:
set for hearing on September 19, 2011. Dkt. No. 98. In support of that motion, Defendants 7 attached as Exhibit C to the Declaration of L. Timothy Fisher the transcript of the February 17,
Plaintiff Facebook, Inc. ("Plaintiff") and defendants Power Ventures, Inc., Steve Vachani,
WHEREAS, on May 9, 2011, Defendants filed a Motion for Summary Judgment, which is
2011 Deposition of Craig Clark, in-house counsel at Facebook. Id. Ex. C. Defendants lodged the 9 exhibit under seal, because it had been designated confidential pursuant to the Stipulated Protective 10
WHEREAS, counsel for Plaintiff and Defendants have since met and conferred regarding the confidentiality designation of the Clark deposition transcript.
the Clark deposition transcript, except for pages 41:7 through 44:15, which will remain designated 15 as confidential.
waiving their right to challenge the confidentiality designation of pages 41:7 through 44:15 at a 18 later date.
Judgment, as those portions are no longer designated as confidential.
WHEREAS, counsel for Plaintiff has agreed to remove the confidential designation from
WHEREAS, counsel for Plaintiff and Defendants have agreed that Defendants are not
WHEREAS, Defendants agree to withdraw the entire Clark deposition transcript filed as
Exhibit C to the Declaration of L. Timothy Fisher in Support of Defendants' Motion for Summary 21
WHEREAS, Defendants agree to re-file the Declaration of L. Timothy Fisher with Exhibit
C containing only portions of the Clark deposition cited in Defendants' Motion for Summary 24
IT IS SO STIPULATED.
ATTESTATION OF FILER
Pursuant to General Order No. 45, Section X, Subparagraph B, the undersigned attests that all parties have concurred in the filing of this stipulation.
Dated: June 7, 2011
L. Timothy Fisher
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