`
`
`
`QUINN EMANUEL URQUHART
` & SULLIVAN, LLP
`James R. Asperger (Bar No. 83188)
`jimasperger@quinnemanuel.com
`Rachael McCracken
`rachaelmccracken@quinnemanuel.com
`865 South Figueroa Street, 10th Floor
`Los Angeles, CA 90017-2543
`Telephone: (213) 443-3000
`Facsimile: (213) 443-3100
`
`QUINN EMANUEL URQUHART
` & SULLIVAN, LLP
`Kevin P.B. Johnson (Bar No. 177129)
`kevinjohnson@quinnemanuel.com
`Todd M. Briggs (Bar No. 209282)
`toddbriggs@quinnemanuel.com
`Brice C. Lynch (Bar No. 288567)
`bricelynch@quinnemanuel.com
`555 Twin Dolphin Drive, 5th Floor
`Redwood Shores, California 94065
`Telephone: (650) 801-5000
`Facsimile: (650) 801-5100
`
`QUINN EMANUEL URQUHART
` & SULLIVAN, LLP
`Eric Huang (pro hac vice)
`erichuang@quinnemanuel.com
`51 Madison Avenue, 22nd Floor
`New York, New York 10010
`Telephone: (212) 849-7000
`Facsimile: (212) 849-7100
`
`Attorneys for Plaintiffs
`NANTWORKS, LLC and NANT HOLDINGS IP, LLC
`
`
`
`
`UNITED STATES DISTRICT COURT
`
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
`
`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
`
`
`
`NANTWORKS, LLC, a Delaware
`limited liability company, and NANT
`HOLDINGS IP, LLC, a Delaware
`limited liability company,
`
`
`Plaintiffs,
`
`
`BANK OF AMERICA
`CORPORATION, a Delaware
`corporation, and BANK OF
`AMERICA, N.A., a national banking
`association,
`
`
`vs.
`
`Defendants.
`
`
` CASE NO. 2:20-cv-7872-GW-PVC
`
`PLAINTIFFS’ APPLICATION TO
`FILE DOCUMENTS UNDER SEAL
`
`
`Judge: Hon. George H. Wu
`Ctrm: 9D
`
`
`Case No. 2:20-cv-7872-GW-PVC
`PLAINTIFFS’ APPLICATION TO FILE DOCUMENTS UNDER SEAL
`
`
`
`
`
`
`
`
`
`
`
`
`
`Case 2:20-cv-07872-GW-PVC Document 438 Filed 05/17/24 Page 2 of 3 Page ID #:53771
`
`
`
`
`PLEASE TAKE NOTICE that pursuant to Civil Local Rule 79-5, Plaintiffs
`
`NantWorks, LLC, and Nant Holdings IP, LLC (collectively, “NantWorks”),
`
`respectfully submit this application to the Court for an order sealing the materials
`
`described below that are filed in connection with Plaintiffs’ Opposition to Defendants’
`
`Motion to Exclude Certain Opinions of Dan Schonfeld (“Opposition to Motion to
`
`Exclude”). This application pertains to the following items:
` Plaintiffs’ Opposition to Motion to Exclude;
` Exhibits 1 to the Declaration of Brice C. Lynch in Support of Plaintiffs’
`Opposition to Motion to Exclude.
`
`
`
`
`
`As set forth in the Declaration of Brice C. Lynch in Support of Plaintiffs’
`
`Application to File Under Seal submitted herewith, the material described above are:
`
`a) the Expert Report of Cathy Glassman served on January 30, 2024, which was
`
`designated “Highly Confidential – Attorney Eyes Only”;
`
`b) Plaintiffs’ Opposition to Defendants’ Motion to Exclude, which contains
`
`quotations from, references to, and descriptions of statements made in the
`
`document referenced above in (a) and other documents currently under seal.
`
`
`
`Pursuant to L.R. 79-5.2.2, NantWorks conferred with BoA and BoA
`
`confirmed that they do not object sealing these materials to be filed with NantWorks’
`
`Opposition to Motion to Strike.
`
`
`
`Accordingly, NantWorks respectfully requests for an order permitting that the
`
`following documents be filed under seal:
`
`i. Plaintiffs’ Opposition to Motion to Exclude;
`
`ii. Exhibit 1 to the Declaration of Brice C. Lynch in Support of Plaintiffs’
`
`Opposition to Motion to Exclude.
`
`
`
`
`
`
`
`-1-
`Case No. 2:20-cv-7872-GW-PVC
`PLAINTIFFS’ APPLICATION TO FILE DOCUMENTS UNDER SEAL
`
`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
`
`
`
`
`
`Case 2:20-cv-07872-GW-PVC Document 438 Filed 05/17/24 Page 3 of 3 Page ID #:53772
`
`
`DATED: May 17, 2024
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`
`By
`/s/ Todd M. Briggs
`James R. Asperger
`Kevin P.B. Johnson
`Todd M. Briggs
`Eric Huang
`Brice C. Lynch
`
`Attorneys for Plaintiff, NANTWORKS,
`LLC and NANT HOLDINGS IP, LLC
`
`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
`
`
`
`
`
`
`
`-2-
`Case No. 2:20-cv-7872-GW-PVC
`PLAINTIFFS’ APPLICATION TO FILE DOCUMENTS UNDER SEAL
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
