`
`IRELL & MANELLA LLP
`Jonathan S. Kagan (SBN 166039)
`jkagan@irell.com
`Alan Heinrich (SBN 212782)
`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 JOSHUA GLUCOFT
`)
`IN SUPPORT OF JUNIPER NETWORKS,
`)
`INC.’S ADMINISTRATIVE MOTION TO
`)
`FILE UNDER SEAL
`)
`
`)
`
`)
`)
`)
`
`
`FINJAN, INC.,
`
`Plaintiff,
`
`vs.
`
`
`JUNIPER NETWORKS, INC.,
`
`Defendant.
`
`
`
`
`
`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
`
`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`
`
`
`
`- 1 -
`
`DECLARATION OF JOSHUA GLUCOFT ISO JUNIPER'S
`ADMINISTRATIVE MOTION TO FILE UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`
`
`
`Case 3:17-cv-05659-WHA Document 542-1 Filed 06/20/19 Page 2 of 2
`
`DECLARATION OF JOSHUA GLUCOFT
`I, Joshua Glucoft, 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 June 20, 2019, Administrative
`Motion to File Under Seal.
`3.
`I have reviewed the following documents and confirmed that plaintiff Finjan, Inc.
`(“Finjan”) designated them as confidential pursuant to the stipulated Protective Order in this matter:
`Document
`Description
`Portion to Be
`Designating
`Sealed
`Party
`Entirety
`Finjan
`
`Ex. A to Juniper’s
`motion to compel
`documents related to
`Trustwave
`
`Ex. 2 to Juniper’s
`motion to compel
`documents related to
`Trustwave
`
`
`
`
`
`Plaintiff Finjan, Inc.’s
`Objections And Responses To
`Defendant Juniper Networks,
`Inc.’s First Set Of
`Interrogatories (Nos. 1-10)
`Plaintiff Finjan, Inc.’s
`Objections And Responses To
`Defendant Juniper Networks,
`Inc.’s First Set Of
`Interrogatories (Nos. 1-10)
`
`Entirety
`
`Finjan
`
`
`
`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
`
`4.
`Juniper seeks leave to file these documents under seal because Finjan designated
`these documents as “Highly Confidential – Attorneys’ Eyes Only.”
`Executed on June 20, 2019, at Los Angeles, 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/ Joshua Glucoft
`Joshua Glucoft
`Attorney for Defendant
`Juniper Networks, Inc.
`DECLARATION OF JOSHUA GLUCOFT ISO JUNIPER'S
`ADMINISTRATIVE MOTION TO FILE UNDER SEAL
`Case No. 3:17-cv-05659-WHA
`
`
`IRELL & MANELLA LLP
`A Registered Limited Liability
`Law Partnership Including
`Professional Corporations
`
`
`
`
`
`- 2 -
`
`
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
