Google, Inc. v. Affinity Engines, Inc. Doc.

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Case 5:05-cv-00598-JW Document 20 Filed 04/18/2005 Page 1 of 2

1 JAMES A. DIBOISE, State Bar No. 83296 (jdiboise@wsgr.com)

COLLEEN BAL, State Bar No. 167637 (cbal@wsgr.com)
2 WILSON SONSINI GOODRICH & ROSATI
Professional Corporation
3 650 Page Mill Road
Palo Alto, CA 94304-1050
4 Telephone: (650) 493-9300
Facsimile: (650) 565-5100
5
Attorneys for Plaintiff
6 Google Inc.

7
UNITED STATES DISTRICT COURT
8
NORTHERN DISTRICT OF CALIFORNIA
9
SAN JOSE DIVISION
10

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GOOGLE INC., ) CASE NO.: C-05-00598 JW (HRL)
12 )
) DECLARATION OF COLLEEN
13 ) BAL IN SUPPORT OF PLAINTIFF
) GOOGLE INC.’S
14 v. ) MISCELLANEOUS
) ADMINISTRATIVE REQUEST TO
15 AFFINITY ENGINES, INC., ) FILE DOCUMENTS UNDER SEAL
) PURSUANT TO CIVIL LOCAL
16 ) RULES 7-10(b) AND 79-5
)
17 ) Date: May 9, 2005
) Time: 9:00 a.m.
18 ) Judge: Honorable James Ware
) Courtroom: 8, 4th Floor
19 )

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DECL. ISO GOOGLE’S MISC. ADMIN. REQUEST 2633966_1.DOC

TO FILE UNDER SEAL - CASE NO.: 05-00598 JW (HRL)

Dockets.Justia.com
 Case 5:05-cv-00598-JW Document 20 Filed 04/18/2005 Page 2 of 2

1 I, Colleen Bal, declare as follows:

2 1. I am an attorney at law duly licensed to practice in the State of California and

3 before this Court. I am a member of Wilson Sonsini Goodrich & Rosati, counsel for defendant

4 and counterclaimant Google Inc. (“Google”). I have personal knowledge of the facts set forth

5 herein and, if called as a witness, could and would testify competently thereto.

6 2. I submit this declaration in support of Google’s Miscellaneous Administrative

7 Request to File Under Seal, Pursuant to Local Rules 7-10(b) and 79-5, Exhibits A and B to the

8 Declaration of David H. Kramer In Support of Google Inc.’s Opposition to Affinity Engines,

9 Inc.’s Motion to Dismiss and/or Stay Proceedings (“Kramer Declaration”).

10 3. The documents attached as Exhibits A and B to the Kramer Declaration were

11 produced by Google in the state court action Affinity Engines, Inc. v. Google Inc., Santa Clara

12 County Superior Court, Case No. 104CV020368. They contain employment information

13 concerning one of Google’s employees. Exhibits A and B have been designated “Highly

14 Confidential – Attorneys’ Eyes Only” pursuant to the Protective Order entered in that matter on

15 August 23, 2004.

16 4. In light of the designation, Google requests an order permitting it to file Exhibits

17 A and B to the Kramer Declaration under seal.

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

20 foregoing is true and correct. Executed on April 18, 2005, at Palo Alto, California.

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/s/ Colleen Bal
22 Colleen Bal
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DECL. ISO GOOGLE’S MISC. ADMIN. REQUEST -1-

TO FILE UNDER SEAL - CASE NO.: 05-00598 JW (HRL)