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8 2. Pursuant to Northern District of California Civil Local Rules (“Civil Local Rules”) 7-
9 11 and 79-5(d), and the Protective Order entered in this action on January 7, 2010, see Doc #361,
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Plaintiffs have concurrently filed a motion for administrative relief to file certain documents, or
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portions thereof, under seal (“Administrative Motion”) because they have been designated “Highly
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Confidential” by Proponents:
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3. Plaintiffs have concurrently submitted the Administrative Motion because they wish to
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15 introduce these documents received from Proponents as evidence at trial, which has already
16 commenced. Plaintiffs received the documents on January 10, 2010, following this Court’s January
23 counsel for Proponents, requesting that Proponents stipulate to a shortened schedule for resolving this
24 question. Specifically, I requested that Proponents stipulate that they would file and serve a
25 declaration with the Court establishing why all or part of the designated information is sealable or
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withdrawing their designation by no later than January 12, 2010 at 8:00 AM pursuant to Local Rules
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6-2 and 79-5(d). A true and correct copy of the e-mail is attached hereto as Exhibit A.
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7 8. I do not believe that the requested time modification would have any effect on the
8 schedule for this case. Indeed, given that Proponents produced these documents less than two days
9 ago, and trial has already commenced, Plaintiffs would be prejudiced if the requested time
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modification was not granted.
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I declare under penalty of perjury that the foregoing is true and correct. Executed this 12th
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day of January, 2010.
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14 By: /s/
Rebecca Justice Lazarus
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Exhibit A
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