MOTION to Seal Exhibits and Portions of Appendix and Memorandum in Support of Motion to Compel by Commonwealth of Virginia, State of Arizona, State of California, State of Colorado, State of Connecticut, State of Illinois, State of Michigan, State of Minnesota, State of Nebraska, State of New Hampshire, State of New Jersey, State of New York, State of North Carolina, State of Rhode Island, State of Tennessee, State of Washington, State of West Virginia, United States of America. (Attachments: # (1) Proposed Order)(Teitelbaum, Aaron)
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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES, et al.,
Plaintiffs,
v.
GOOGLE LLC,
Defendant.
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No. 1:23-cv-00108-LMB-JFA
PLAINTIFFS’ MOTION FOR LEAVE TO FILE UNDER SEAL
Pursuant to Local Civil Rule 5(C) and the Protective Order (Dkt. 98), Plaintiffs, through
their undersigned counsel, hereby respectfully move this Court to seal the exhibits attached to
their Memorandum of Law in Support of Plaintiffs’ Motion for In Camera Inspection and To
Compel Production of Documents Wrongfully Withheld as Privileged, as well as certain portions
of its Memorandum of Law that reference those exhibits. These exhibits and portions of the brief
contain material Defendant Google and non-party Lazard Frères & Co. LLC have designated as
confidential or highly confidential. Consistent with the local rule and this Court’s Electronic
Case Filing Policies and Procedures, undersigned counsel have filed the materials at issue using
the sealed filing event on CM/ECF and hereby certify that they will serve a copy on opposing
counsel and deliver a copy to this Court in a separate container labeled “UNDER SEAL.” The
grounds for this motion are contained in the memorandum of law concurrently filed in support of
this motion. A proposed order is attached for the Court’s convenience.Page 2 PageID#
Dated: May 19, Respectfully submitted,
JESSICA D. ABER
United States Attorney
JASON S. MIYARES
Attorney General of Virginia
/s/ Gerard Mene
GERARD MENE
Assistant U.S. Attorney
2100 Jamieson Avenue
Alexandria, VA Telephone: (703) 299-Facsimile: (703) 299-Email: Gerard.Mene@usdoj.gov
/s/ Andrew N. Ferguson
ANDREW N. FERGUSON
Solicitor General
STEVEN G. POPPS
Deputy Attorney General
TYLER T. HENRY
Assistant Attorney General
/s/ Julia Tarver Wood
JULIA TARVER WOOD
/s/ David M. Teslicko
DAVID M. TESLICKO
ALVIN H. CHU
AARON M. TEITELBAUM
United States Department of Justice
Antitrust Division
450 Fifth Street NW, Suite Washington, DC Telephone: (202) 307-Fax: (202) 616-Email: Julia.Tarver.Wood@usdoj.gov
Attorneys for the United States
Office of the Attorney General of Virginia
202 North Ninth Street
Richmond, VA Telephone: (804) 692-Facsimile: (804) 786-Email: thenry@oag.state.va.us
Attorneys for the Commonwealth of
Virginia and local counsel for the
States of Arizona, California,
Colorado, Connecticut, Illinois,
Michigan, Minnesota, Nebraska, New
Hampshire, New Jersey, New York,
North Carolina, Rhode Island,
Tennessee, Washington, and West
Virginia
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:23-cv-00108-LMB-JFA Document 217 Filed 05/19/23 Page 1 of 2 PageID# 1569
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES, et al.,
Plaintiffs,
v.
GOOGLE LLC,
Defendant.
)
)
)
)
)
)
)
)
No. 1:23-cv-00108-LMB-JFA
PLAINTIFFS’ MOTION FOR LEAVE TO FILE UNDER SEAL
Pursuant to Local Civil Rule 5(C) and the Protective Order (Dkt. 98), Plaintiffs, through
their undersigned counsel, hereby respectfully move this Court to seal the exhibits attached to
their Memorandum of Law in Support of Plaintiffs’ Motion for In Camera Inspection and To
Compel Production of Documents Wrongfully Withheld as Privileged, as well as certain portions
of its Memorandum of Law that reference those exhibits. These exhibits and portions of the brief
contain material Defendant Google and non-party Lazard Frères & Co. LLC have designated as
confidential or highly confidential. Consistent with the local rule and this Court’s Electronic
Case Filing Policies and Procedures, undersigned counsel have filed the materials at issue using
the sealed filing event on CM/ECF and hereby certify that they will serve a copy on opposing
counsel and deliver a copy to this Court in a separate container labeled “UNDER SEAL.” The
grounds for this motion are contained in the memorandum of law concurrently filed in support of
this motion. A proposed order is attached for the Court’s convenience.
PDF Page 3
Case 1:23-cv-00108-LMB-JFA Document 217 Filed 05/19/23 Page 2 of 2 PageID# 1570
Dated: May 19, 2023
Respectfully submitted,
JESSICA D. ABER
United States Attorney
JASON S. MIYARES
Attorney General of Virginia
/s/ Gerard Mene
GERARD MENE
Assistant U.S. Attorney
2100 Jamieson Avenue
Alexandria, VA 22314
Telephone: (703) 299-3777
Facsimile: (703) 299-3983
Email: Gerard.Mene@usdoj.gov
/s/ Andrew N. Ferguson
ANDREW N. FERGUSON
Solicitor General
STEVEN G. POPPS
Deputy Attorney General
TYLER T. HENRY
Assistant Attorney General
/s/ Julia Tarver Wood
JULIA TARVER WOOD
/s/ David M. Teslicko
DAVID M. TESLICKO
ALVIN H. CHU
AARON M. TEITELBAUM
United States Department of Justice
Antitrust Division
450 Fifth Street NW, Suite 7100
Washington, DC 20530
Telephone: (202) 307-0077
Fax: (202) 616-8544
Email: Julia.Tarver.Wood@usdoj.gov
Attorneys for the United States
Office of the Attorney General of Virginia
202 North Ninth Street
Richmond, VA 23219
Telephone: (804) 692-0485
Facsimile: (804) 786-0122
Email: thenry@oag.state.va.us
Attorneys for the Commonwealth of
Virginia and local counsel for the
States of Arizona, California,
Colorado, Connecticut, Illinois,
Michigan, Minnesota, Nebraska, New
Hampshire, New Jersey, New York,
North Carolina, Rhode Island,
Tennessee, Washington, and West
Virginia
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