`
`IRELL & MANELLA LLP
`Jonathan S. Kagan (SBN 166039)
`jkagan@irell.com
`Joshua P. Glucoft (SBN 301249)
`jglucoft@irell.com
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067-4276
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
`
`Rebecca L. Carson (SBN 254105)
`rcarson@irell.com
`Ingrid M. H. Petersen (SBN 313927)
`ipetersen@irell.com
`Kevin Wang (SBN 318024)
`kwang@irell.com
`840 Newport Center Drive, Suite 400
`Newport Beach, California 92660-6324
`Telephone: (949) 760-0991
`Facsimile: (949) 760-5200
`
`Attorneys for Defendant
`JUNIPER NETWORKS, INC.
`
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN FRANCISCO DIVISION
`)
`Case No. 3:17-cv-05659-WHA
`)
`
`DECLARATION OF INGRID PETERSEN
`)
`IN SUPPORT OF JUNIPER NETWORKS,
`)
`INC.’S ADMINISTRATIVE MOTION TO
`)
`FILE UNDER SEAL
`)
`
`)
`
`)
`)
`)
`
`
`FINJAN, INC.,
`
`Plaintiff,
`
`vs.
`
`
`JUNIPER NETWORKS, INC.,
`
`Defendant.
`
`
`
`
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`
`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`
`
`
`
`- 1 -
`
`DECLARATION OF INGRID PETERSEN ISO JUNIPER'S
`ADMINISTRATIVE MOTION TO FILE UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`
`
`
`Case 3:17-cv-05659-WHA Document 439-2 Filed 04/18/19 Page 2 of 3
`
`DECLARATION OF INGRID PETERSEN
`I, Ingrid Petersen, declare as follows:
`1.
`I am an attorney at the law firm of Irell & Manella LLP, counsel of record for Juniper
`Networks, Inc. (“Juniper”) in the above-captioned matter. I am a member in good standing of the
`State Bar of California and have been admitted to practice before this Court. I have personal
`knowledge of the facts set forth in this Declaration and, if called as a witness, could and would
`testify competently to such facts under oath.
`2.
`I submit this declaration in support of Juniper’s April 18, 2019, Administrative
`Motion to File Under Seal.
`3.
`I am informed and believe that good cause and compelling reasons exist for sealing
`the following:
`Document
`
`Basis for Sealing
`
`Designating Party
`
`Portion to Be
`Sealed
`Portions on
`page 2:1, 5, 6-
`10.
`
`Portions on
`page 3:11-15.
`
`Defendant Juniper
`Network Inc.’s Reply
`in Support of Motion
`for Sanctions
`
`Ex. A to Juniper’s
`Reply
`Ex. B to Juniper’s
`Reply
`Ex. C to Juniper’s
`Reply
`
`
`
`Confidential Third-Party
`Information
`
`Joe Security
`
`Court Has Sealed Dkt.
`283
`
`Court
`
`Entire Exhibit Confidential Third-Party
`Information
`Entire Exhibit Confidential Third-Party
`Information
`Entire Exhibit Confidential Third-Party
`Information
`
`Joe Security
`
`Joe Security
`
`Joe Security
`
`4.
`It is my understanding that the Court has sealed Dkt. 283.
`5.
`Additionally, it is my understanding Joe Security LLC considers the documents in
`Exhibits A, B, and C to be confidential.
`6.
`I, therefore, believe that good cause and compelling reasons exist.
`
`
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`
`
`
`
`- 2 -
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`DECLARATION OF INGRID PETERSEN ISO JUNIPER'S
`ADMINISTRATIVE MOTION TO FILE UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`
`
`
`Case 3:17-cv-05659-WHA Document 439-2 Filed 04/18/19 Page 3 of 3
`
`Executed on April 18, 2019, at Newport Beach, California.
`I declare under penalty of perjury under the laws of the United States of America that the
`foregoing is true and correct to the best of my knowledge.
`
`
`
`/s/ Ingrid Petersen
`Ingrid Petersen
`Attorney for Defendant
`Juniper Networks, Inc.
`
`
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`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`
`
`
`
`- 3 -
`
`DECLARATION OF INGRID PETERSEN ISO JUNIPER'S
`ADMINISTRATIVE MOTION TO FILE UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`
`
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