Case 2:15-cv MMD-GWF Document 50 Filed 09/19/16 Page 1 of 4

Similar documents
) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

DISTRICT COURT, FAMILY DIVISION CLARK COUNTY, NEVADA

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA (OAKLAND DIVISION)

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

IN THE TENTH JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA IN AND FOR THE COUNTY OF CHURCHILL

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA - SACRAMENTO DIVISION } } } } } } } } } } } } } } /

AS MODIFIED. Attorneys for Plaintiff, STERLING SAVINGS BANK UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

PREPARATION OF A TRIAL STATEMENT

Case 2:18-cv R-AGR Document 7 Filed 02/05/18 Page 1 of 2 Page ID #:26

Case 2:14-cv WBS-EFB Document 14 Filed 08/07/14 Page 1 of 5

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES - CENTRAL DISTRICT ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case btb Doc 249 Entered 05/19/17 16:27:09 Page 1 of 6 UNITED STATES BANKRUPTCY COURT DISTRICT OF NEVADA. Chapter 7

DEFAULT PACKET P-1. The District Court Filing Office is located on the first floor at: 75 Court Street Reno, NV 89501

NOTICE OF CHANGE OF ADDRESS F-5. The District Court Filing Office is located on the first floor at: 75 Court Street Reno, NV 89501

COMES NOW San Juan County and moves the Court to defer consideration

Case 2:17-ap BB Doc 50 Filed 05/04/17 Entered 05/04/17 14:14:01 Desc Main Document Page 1 of 6

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Federal Pro Se Clinic CENTRAL DISTRICT OF CALIFORNIA

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA SECOND APPELLATE DISTRICT. Plaintiffs and Appellants, Defendants and Res ondents.

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) )

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA FOURTH APPELLATE DISTRICT. DIVISION [Number]

Case3:11-cv WHA Document33 Filed01/06/12 Page1 of 11 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA. Plaintiff, Plaintiffs,

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

)

United States District Court District of Utah

Part Description 1 5 pages 2 Proposed Order Proposed Order to Motion for Summary Judgment

copy 6 Attorneys for Plaintiff CALMAT CO. dba VTJLCAN MATERIALS COMPANY, WESTERN DIVISION 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA

Attorneys for Defendant and Respondent CITY OF ANAHEIM SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE, CENTRAL JUSTICE CENTER

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA * * *

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

Case M:06-cv VRW Document 424 Filed 02/04/2008 Page 1 of 5

Exempt from filing fee Gov't Code Secs. 6100, 6103 NOTICE OF UNAVAILABILITY OF COUNSEL

Case 2:16-cv MMD-CWH Document 1 Filed 01/05/16 Page 1 of 5

Case 3:16-cv CRS-CHL Document 36 Filed 06/29/17 Page 1 of 5 PageID #: 423

Case 1:18-cv CG-B Document 18 Filed 03/20/18 Page 1 of 3

Case 5:15-cv VAP-KK Document 73 Filed 12/04/15 Page 1 of 16 Page ID #:2332

) ) ) ) ) ) ) ) ) ) ) )

CASE NO: FORECLOSURE SCHEDULING ORDER. 1. Any prior order referring this case to Senior Judge Sandra Taylor is hereby VACATED.

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SACRAMENTO

LAW OFFICES OF MICHAEL D.

[PROPOSED] JUDGMENT GRANTING PEREMPTORY WRIT OF MANDATE

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

Potential Investment Agreement. Dated as of, 2017

Case 2:00-cv GAF-RC Document 435 Filed 05/14/13 Page 1 of 6 Page ID #:1893

IN THE COURT OF APPEAL STATE OF CALIFORNIA FOURTH APPELLATE DISTRICT DIVISION THREE

Case 2:06-cv R-CW Document 437 Filed 10/12/12 Page 1 of 11 Page ID #:7705

SUPERIOR COURT OF THE STATE OF CALIFORNIA

REQUEST FOR PUBLICATION OF OPINION. Andre Torigian v. WT Capital Lender Services Case No. F (Fresno County Superior Court No.

Case 3:05-cv Document 22 Filed 06/09/2006 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO. The Motion of Plaintiff Leonard Labow in the above-entitled action, for an

Petition, there is. staff for this form. the other party s

LOCAL OPERATING PROCEDURES UNITED STATES IMMIGRATION COURT BUFFALO & BATAVIA, NEW YORK

1. TRCP 194 created a new discovery tool entitled Requests for Disclosure.

Case 2:13-cv BJR Document 12 Filed 06/21/13 Page 1 of 7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE

IN THE CIRCUIT COURT FOR THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH

SAMPLE FORM F NOTICE DESIGNATING RECORD ON APPEAL

UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION


Case 1:16-cv SS Document 85 Filed 07/28/16 Page 1 of 4 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

Case 2:17-ap BB Doc 24 Filed 03/21/17 Entered 03/21/17 10:59:09 Desc Main Document Page 1 of 6

LAKE FOREST PARK MUNICIPAL COURT

AGREED PROTECTIVE ORDER IN INSURANCE CASE

MOTION FOR LEAVE TO AMEND COMPLAINT

~IE EIVIEIQ) UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ALASKA RESPONSE TO PLAINTIFF'S INJUNCTION AND

Case 2:16-cv RAJ Document 8 Filed 03/30/16 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

IN THE CIRCUIT COURT FOR THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH COUNSEL

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF LOS ANGELES ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT DISTICT OF UTAH, CENTRAL DIVISION

in furtherance of and in response to its Tentative Decision dated 1/4/2010 addressing various matters

Case 2:07-cv KJD-RJJ Document 95 Filed 02/04/10 Page 1 of 9

Case 2:15-cv DN-EJF Document 517 Filed 11/28/18 Page 1 of 11

1 The parties to this action, through their respective counsel, hereby stipulate and agree to. 2 the following:

TO BE FILED IN THE COURT OF APPEAL

2:11-cv R -JCG Document 58 Filed 01/06/12 Page 1 of 6 Page ID #:699

At Part of the Supreme Court of the. of New York, at the Courthouse thereof, 60 PLAINTIFF, DEFENDANTS.

Doe v. Project Fair Bid, Inc. et al Doc. 1 Att. 1 EXHIBIT A. Dockets.Justia.com

Case 2:07-cv RCJ-GWF Document 1 Filed 12/26/2007 Page 1 of 6

Case5:12-cv HRL Document9 Filed08/09/12 Page1 of 5

EX PARTE MOTION FOR PUBLICATION OF CITATION TO APPEAR AND SHOW CAUSE FOR MINOR GUARDIANSHIP G-7

Case gwz Doc 226 Entered 01/03/11 17:27:13 Page 1 of 19

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES ) ) ) ) ) )

F ADV.NOTICE.LODGMENT

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

NEVADA STATE CONTRACTORS

- UNITED STATES DISTRICT COURT,_. SOUTHERN DISTRICT OF NEW YORK

UNITED STATES COURT OF APPEALS FOR THE TENTH CIRCUIT. Plaintiff-Appellee, Defendants-Appellants.

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA. CASE NO.: Civ-Martinez

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

Case 2:11-cv BSJ Document 209 Filed 09/13/12 Page 1 of 5

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES

SUPERIOR COURT OF CALIFORNIA COUNTY OF SONOMA ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA ) ) ) ) ) ) No. 2:10-cv APG-GWF (Consolidated) CLASS ACTION

2 STEPAN A. HAYTAYAN. 1 KAMALA D. HARRIS Attorney General of California

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI HATTIESBURG DIVISION CIVIL ACTION NO.

Transcription:

Samick Musical Instruments Co., Ltd. v. QRS Music Technologies, Inc. et al Doc. Case :-cv-00-mmd-gwf Document 0 Filed 0// Page of 0 0 BROWNSTEIN HYATT FARBER SCHRECK, LLP Matthew D. Francis Nevada Bar No. Arthur A. Zorio State Bar No. Kietzke Lane Reno, NV Telephone: () -00 Facsimile: () - Email: mfrancis@bhfs.com Email: azorio@bhfs.com CHOI CAPITAL LAW Boyoon Choi (Pro Hac Vice) Washington Bar No. 0 Pike Tower, Suite Seattle, WA 0 Telephone: (0) -0 Facsimile: (0) -0 Email: b.choi@choicapitallaw.com Attorneys for Plaintiff Samick Musical Instruments Co., Ltd. SAMICK MUSICAL INSTRUMENTS CO., LTD., a Korean limited company, vs. UNITED STATES DISTRICT COURT Plaintiff/ Counter-Defendant QRS MUSIC TECHNOLOGIES, INC., a Delaware corporation; THOMAS DOLAN, an Individual, Defendants/ Counter-Plaintiff DISTRICT OF NEVADA Case No. :-cv-00-mmd-gwf PLAINTIFF S MOTION FOR LEAVE TO FILE THE FOLLOWING UNDER SEAL:. PLAINTIFFS MOTION FOR LEAVE TO AMEND COMPLAINT AND REOPEN DISCOVERY AND EXHIBITS THERETO; AND. AMENDED COMPLAINT AND EXHIBITS THERETO UNDER SEAL MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF ; [PROPOSED] ORDER Plaintiff Samick Musical Instruments Co., Ltd. ( Plaintiff or Samick ) hereby moves this Court for an order sealing Plaintiffs Motion For Leave To Amend Complaint And Reopen -- Dockets.Justia.com

Case :-cv-00-mmd-gwf Document 0 Filed 0// Page of 0 0 Discovery and the Exhibits thereto ( Motion ), and the Amended Complaint along with its Exhibits. These documents are filed concurrently with this Motion. In January 00, Plaintiff Samick and QRS Music Technologies, Inc. ( Defendant QRS ) entered into an Agreement. See September, 0 declaration of Boyoon Choi,. This Agreement forms the basis for the majority of the claims being presently asserted by Plaintiff Samick against Defendant QRS. Id. The 00 Agreement contains a strict confidentiality provision prohibiting disclosure of the terms of the 00 Agreement and its accompanying Exhibits to any third party. Id.,. The parties have also agreed to keep confidential and under seal the deposition testimony regarding the parties financial information. Id. Seeking to honor this Agreement and not breach the terms of the confidentiality provision, Plaintiff seeks permission to file under seal the full version of the Amended Complaint, the 00 Agreement and its Attachments, as well as the Motion Id.. A redacted version of the Amended Complaint with non-confidential Exhibits A and B has been filed concurrently herewith. Id. As stated above, the Amended Complaint has been redacted because many of the facts and causes of action refer directly to the terms of the 00 Agreement. Id. Likewise, Plaintiff seeks to have the Motion and its Exhibits filed under seal to honor the Agreement, and protect the confidential financial information of the parties. Id.,. LR 0-(b) provides in part papers filed with the Court under seal shall be accompanied by a motion for leave to file those documents under seal, and shall be filed in accordance with the Court s electronic filing procedures. Previously, this Court granted Plaintiff s motion to file the Original Complaint under seal. Doc. #. In good faith, seeking to honor and not breach the terms of the parties 00 Agreement, Plaintiff Samick requests that this Court grant its Motion to file Plaintiffs Motion For Leave To --

Case :-cv-00-mmd-gwf Document 0 Filed 0// Page of Amend Complaint And Reopen Discovery and Exhibits thereto, as well as the Amended Complaint along with Exhibits under seal. 0 0 Dated: September, 0 By: /s/ Matthew D. Francis BROWNSTEIN HYATT FARBER SCHRECK, LLP Matthew D. Francis Arthur A. Zorio Kietzke Lane Reno, NV By: /s/ Boyoon Choi CHOI CAPITAL LAW PLLC Boyoon Choi 0 Pike Tower, Suite Seattle, WA 0 Attorneys for Plaintiff Samick Musical Instruments Co., Ltd. IT IS ORDERED: UNITED STATES DISTRICT MAGISTRATE JUDGE JUDGE DATED: September, 0 --

Case :-cv-00-mmd-gwf Document 0 Filed 0// Page of 0 0 CERTIFICATE OF SERVICE Pursuant to FRCP (b), I certify that I am an employee of Brownstein Hyatt Farber Schreck, LLP, and on this th day of September, 0, I served the document entitled PLAINTIFF S MOTION FOR LEAVE TO FILE THE FOLLOWING UNDER SEAL:. PLAINTIFFS MOTION FOR LEAVE TO AMEND COMPLAINT AND REOPEN DISCOVERY AND EXHIBITS THERETO; AND. AMENDED COMPLAINT AND EXHIBITS THERETO UNDER SEAL, MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF; [PROPOSED] ORDER, on the parties listed below via the following: DICKINSON WRIGHT PLLC Eric D. Hone Gabriel A. Blumberg West Sunset Road, Suite 00 Las Vegas, Nevada ehone@dickinsonwright.com gblumberg@dickinsonwright.com CLYDE SNOW & SESSIONS Jonathan Dale Bletzacker Walter A. Romney, Jr. 0 South Main Street, Suite 00 Salt Lake City, Utah jdb@clydesnow.com war@clydesnow.com Jacob L. Fonnesbeck Smith Corrrell, LLP 0 W. Broadway #00 Salt Lake City, UT 0 jfonnesbeck@smithcorrell.com Attorney for Defendants VIA FIRST CLASS U.S. MAIL: by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid, in the United States mail at Reno, Nevada for delivery to the foregoing. VIA FACSIMILE: by transmitting to a facsimile machine maintained by the person on whom it is served at the facsimile machine telephone number as last given by that person on any document which he/she has filed in the cause and served on the party making the service. The copy of the document served by the facsimile transmission bears a notation of the date and place of transmission and the facsimile telephone number to which it was transmitted. BY PERSONAL SERVICE: by personally hand-delivering or causing to be hand delivered by such designated individual whose particular duties include delivery of such on behalf of the firm, addressed to the individual(s) listed, signed by such individual or his/her representative accepting on his/her behalf. VIA COURIER: by delivering a copy of the document to a courier service for overnight delivery to the foregoing parties. VIA ELECTRONIC SERVICE: by serving via electronic mail. 0\000\0. /s/ Nancy R. Lindsley Employee of Brownstein Hyatt Farber Schreck, LLP --

Case :-cv-00-mmd-gwf Document 0- Filed 0// Page of 0 0 DECLARATION OF BOYOON CHOI I, Boyoon Choi, do hereby declare and state as follows:. I am an attorney at the law firm of Choi Capital Law PLLC located at 0 Pike Street Suite, Seattle, Washington 0. This declaration is based upon my personal knowledge, and is made in support of Plaintiff Samick Musical Instruments Co., Ltd. ( Plaintiff or Samick ) Motion to File the Following Under Seal:. Plaintiffs Motion For Leave To Amend Complaint And Reopen Discovery And Exhibits Thereto; and. Amended Complaint And Exhibits Thereto Under Seal.. In January 00, Plaintiff Samick and QRS Music Technologies, Inc. ( Defendant QRS ) entered into an Agreement. This Agreement forms the basis for the majority of the claims being presently asserted by Plaintiff Samick against Defendant QRS.. The 00 Agreement contains a strict confidentiality provision prohibiting disclosure of the terms of the 00 Agreement and its accompanying Exhibits to any third party. Additionally, the parties have agreed to keep confidential and under seal the deposition testimony regarding the parties financial information.. Seeking to honor the Agreement among the parties, and not breach the terms of the confidentiality provisions, Plaintiff seeks permission to file the Amended Complaint, the 00 Agreement and its Attachments under seal. A redacted version of the Complaint with non-confidential Exhibits A and B were filed to initiate this lawsuit. As stated above, the Amended Complaint has been redacted because many of the facts and causes of action refer directly to the terms of the 00 Agreement. A redacted version of the Amended Complaint accompanies this motion.. Also, the accompanying Plaintiffs Motion For Leave To Amend Complaint And ///// ///// ///// //// ////

Case :-cv-00-mmd-gwf Document 0- Filed 0// Page of Reopen Discovery and exhibits thereto need to be sealed because the same discuss the terms of the Agreement as well as confidential financial information regarding the parties. I declare under penalty of perjury pursuant to the laws of the State of Nevada that the foregoing is true and correct to the best of my knowledge. 0 0 Dated: September, 0 at Seattle Washington. By: /s/ Boyoon Choi BOYOON CHOI

Case :-cv-00-mmd-gwf Document 0- Filed 0// Page of CERTIFICATE OF SERVICE Pursuant to FRCP (b), I certify that I am an employee of Brownstein Hyatt Farber Schreck, LLP, and on this th day of September, 0, I served the document entitled DECLARATION OF BOYOON CHOI IN SUPPORT OF MOTION TO FILE UNDER SEAL, on the parties listed below via the following: 0 DICKINSON WRIGHT PLLC Eric D. Hone Gabriel A. Blumberg West Sunset Road, Suite 00 Las Vegas, Nevada ehone@dickinsonwright.com gblumberg@dickinsonwright.com Jacob L. Fonnesbeck Smith Corrrell, LLP 0 W. Broadway #00 Salt Lake City, UT 0 jfonnesbeck@smithcorrell.com Attorney for Defendants CLYDE SNOW & SESSIONS Jonathan Dale Bletzacker Walter A. Romney, Jr. 0 South Main Street, Suite 00 Salt Lake City, Utah jdb@clydesnow.com war@clydesnow.com 0 VIA FIRST CLASS U.S. MAIL: by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid, in the United States mail at Reno, Nevada for delivery to the foregoing. VIA FACSIMILE: by transmitting to a facsimile machine maintained by the person on whom it is served at the facsimile machine telephone number as last given by that person on any document which he/she has filed in the cause and served on the party making the service. The copy of the document served by the facsimile transmission bears a notation of the date and place of transmission and the facsimile telephone number to which it was transmitted. BY PERSONAL SERVICE: by personally hand-delivering or causing to be hand delivered by such designated individual whose particular duties include delivery of such on behalf of the firm, addressed to the individual(s) listed, signed by such individual or his/her representative accepting on his/her behalf. VIA COURIER: by delivering a copy of the document to a courier service for overnight delivery to the foregoing parties. VIA ELECTRONIC SERVICE: by serving via electronic mail. 0\000\0. /s/ Nancy R. Lindsley Employee of Brownstein Hyatt Farber Schreck,