Free Motion to Seal Document - District Court of California - California

Case 3:07-cv-02748-MHP

Document 89

Filed 02/04/2008

Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

HARVEY SISKIND LLP IAN K. BOYD (State Bar No. 191434) [email protected] SETH I. APPEL (State Bar No. 233421) [email protected] RAFFI V. ZEROUNIAN (State Bar No. 236388) [email protected] Four Embarcadero Center, 39th Floor San Francisco, California 94111 Telephone: (415) 354-0100 Facsimile: (415) 391-7124 Attorneys for Plaintiff and Counterdefendant Mark Lillge d/b/a Creative Marketing Concepts IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION MARK LILLGE d/b/a CREATIVE MARKETING CONCEPTS, Plaintiff, vs. ANDREW VERITY and CHRISTINA CHANG. Defendants. ANDREW VERITY and CHRISTINA CHANG, Counterclaimants, v. MARK LILLGE d/b/a CREATIVE MARKETING CONCEPTS, and DOES 1-10, Counterdefendants. Case No. C 07-02748 MHP PLAINTIFF'S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL RE APPLICATION FOR ORDER TO SHOW CAUSE WHY DEFENDANTS SHOULD NOT BE ADJUDGED IN CONTEMPT AND SANCTIONED

PLAINTIFF'S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL

CASE NO. C 07-02748 MHP

Case 3:07-cv-02748-MHP

Document 89

Filed 02/04/2008

Page 2 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Plaintiff Mark Lillge d/b/a Creative Marketing Concepts ("Plaintiff") hereby moves the Court for an order authorizing the filing of certain documents under seal, pursuant to Local Rules 7-11 and 79-5. The basis of this motion is that these documents, in unredacted form, contain Plaintiff's trade secrets. ADMINISTRATIVE MOTION The documents to be filed under seal are the unredacted Application for Order to Show Cause Why Defendants Not Be Adjudged in Contempt ("Application"), unredacted declaration of one of Plaintiff's customers ("Declaration"), and certain unredacted e-mails to or from Plaintiff's customers ("E-mails"), which are attached as exhibits to the Declaration of Seth I. Appel. The Application, Declaration and E-mails contain information regarding the names and employers of four different individuals who are customers of Plaintiff. The above information derives independent economic value from not being generally known to the public or to Plaintiff's competitors, and it is the subject of efforts that are reasonable under the circumstances to maintain its secrecy. CONCLUSION For the reasons noted above, the Court should issue an order authorizing the filing of the attached document under seal. Plaintiff will file redacted versions of the Application and Declaration, the E-mails as attached to the Declaration of Seth I. Appel, on the public docket, with only the names and employers of these customers redacted.

Dated: February 4, 2008

HARVEY SISKIND LLP

By:

/s/ Ian K. Boyd

Attorneys for Plaintiff and Counterclaim Defendant Mark Lillge d/b/a Creative Marketing Concepts

­1­ PLAINTIFF'S ADMINISTRATIVE MOTION TO FILE DOCUMENTS UNDER SEAL CASE NO. C 07-02748 MHP