`
`Steven Pepe (pro hac vice)
`Cassandra B. Roth
`ROPES & GRAY LLP
`1211 Avenue of the Americas
`New York, NY 10036-8704
`Tel: 212-596-9000
`
`James R. Batchelder (pro hac vice)
`James L. Davis, Jr. (pro hac vice)
`ROPES & GRAY LLP
`1900 University Avenue, 6th Floor
`East Palo Alto, CA 94303-2284
`Tel: 650-617-4000
`
`Scott McKeown (pro hac vice)
`ROPES & GRAY LLP
`2099 Pennsylvania Avenue, NW
`Washington, DC 20006-6807
`Tel: 202-508-4600
`
`Counsel for Defendant
`RAB Lighting Inc.
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF NEW JERSEY
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`SIPCO, LLC,
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`Plaintiff,
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`v.
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`RAB LIGHTING INC.,
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`Defendant.
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`CIVIL ACTION FILE NUMBER:
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`2:18-cv-08962-JLL-CLW
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`Judge Cathy L. Waldor
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`NOTICE OF MOTION TO SEAL
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`Motion Day: October 15, 2018
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`Case 2:18-cv-08962-JLL-CLW Document 35 Filed 09/14/18 Page 2 of 4 PageID: 922
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`PLEASE TAKE NOTICE that on October 15, 2018, at 9:00 a.m., or as soon thereafter
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`as counsel may be heard, the undersigned counsel for defendant RAB Lighting Inc. (“RAB”)
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`shall appear before the Honorable Cathy L. Waldor, U.S.M.J., and shall move this Court,
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`pursuant to Local Civil Rule 5.3(c), for an Order sealing Exhibit A to RAB’s Answer to
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`Plaintiff’s Amended Complaint, Affirmative Defenses, and Counterclaim, which has been
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`electronically filed with the Court. D.I. 30-1.
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`PLEASE TAKE FURTHER NOTICE that in support of their Motion, RAB shall rely
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`upon the accompanying Declaration of Scott Jacobson, submitted herewith. A proposed form of
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`Order with accompanying proposed findings of fact and conclusions of law is also submitted for
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`the Court’s consideration.
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`PLEASE TAKE FURTHER NOTICE that counsel for plaintiff has consented to this
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`motion.
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`
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`Dated: September 14, 2018
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`s/ James R. Batchelder
`s/ Cassandra B. Roth
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`Respectfully submitted,
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`
`
`
`Steven Pepe (pro hac vice)
`Cassandra B. Roth
`ROPES & GRAY LLP
`1211 Avenue of the Americas
`New York, NY 10036-8704
`Telephone: (212) 596-9000
`Facsimile: (212) 596-9090
`Email: cassandra.roth@ropesgray.com
`Email: steven.pepe@ropesgray.com
`
`James R. Batchelder (pro hac vice)
`James L. Davis, Jr. (pro hac vice)
`ROPES & GRAY LLP
`1900 University Avenue, 6th Fl.
`East Palo Alto, CA 94303-2284
`
`-1-
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`
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`Case 2:18-cv-08962-JLL-CLW Document 35 Filed 09/14/18 Page 3 of 4 PageID: 923
`
`Telephone: (650) 617-4000
`Facsimile: (650) 617-4090
`Email: james.batchelder@ropesgray.com
`Email: james.l.davis@ropesgray.com
`
`Scott A. McKeown (pro hac vice)
`ROPES & GRAY LLP
`2099 Pennsylvania Avenue, NW
`Washington, DC 20006-6807
`Telephone: (202) 508-4600
`Facsimile: (202) 508-4650
`Email: scott.mckeown@ropesgray.com
`
`Counsel for Defendant RAB Lighting Inc.
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`-2-
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`Case 2:18-cv-08962-JLL-CLW Document 35 Filed 09/14/18 Page 4 of 4 PageID: 924
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`CERTIFICATE OF SERVICE
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`I hereby certify that on September 14, 2018, the foregoing Notice of Motion to Seal and
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`supporting documents was filed via the Court’s ECF system, which sent electronic copies to all
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`counsel of record.
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`I certify that the foregoing statements made by me are true. I am aware that if any of the
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`foregoing statements are willfully false, I am subject to punishment.
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`
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`Dated: September 14, 2018
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`s/ Matthew R. Shapiro
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`-3-
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`
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