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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA
ALEXANDRIA DIVISION
UNITED STATES, et al.,
Plaintiffs,
vs.
No: 1:23-cv-00108-LMB-JFA
GOOGLE LLC,
Defendant.
DEFENDANT GOOGLE LLC’S MOTION TO SEAL
Pursuant to Local Civil Rule 5(C) and the Protective Order (Dkt. 203), Defendant Google
LLC (“Google”), through its undersigned counsel, hereby respectfully moves this Court to seal
exhibits 2-13 and 15-20 attached to its Opposition to the United States’ Motion for Partial
Judgment on the Pleadings or, in the Alternative, a Protective Order, as well as certain portions of
its Opposition that reference those exhibits (Dkt. 368 & 369). These exhibits and portions of the
brief contain material Plaintiff or a third-party has 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: August 31,
Respectfully submitted,
/s/ Craig C. Reilly
Craig C. Reilly (VSB # 20942)
THE LAW OFFICE OF
CRAIG C. REILLY, ESQ.
209 Madison Street
Alexandria, VA Telephone: (703) 549-Facsimile: (703) 549-craig.reilly@ccreillylaw.com
Eric Mahr (pro hac vice)
Andrew Ewalt (pro hac vice)
Julie Elmer (pro hac vice)
Lauren Kaplin (pro hac vice)
Jeanette Bayoumi (pro hac vice)
Claire Leonard (pro hac vice)
Sara Salem (pro hac vice)
Tyler Garrett (VSB # 94759)
FRESHFIELDS BRUCKHAUS
DERINGER US LLP
700 13th Street, NW, 10th Floor
Washington, DC Telephone: (202) 777-Facsimile: (202) 777-eric.mahr@freshfields.com
Counsel for Defendant Google LLC
PDF Page 1
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Case 1:23-cv-00108-LMB-JFA Document 370 Filed 08/31/23 Page 1 of 2 PageID# 5934
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA
ALEXANDRIA DIVISION
UNITED STATES, et al.,
Plaintiffs,
vs.
No: 1:23-cv-00108-LMB-JFA
GOOGLE LLC,
Defendant.
DEFENDANT GOOGLE LLC’S MOTION TO SEAL
Pursuant to Local Civil Rule 5(C) and the Protective Order (Dkt. 203), Defendant Google
LLC (“Google”), through its undersigned counsel, hereby respectfully moves this Court to seal
exhibits 2-13 and 15-20 attached to its Opposition to the United States’ Motion for Partial
Judgment on the Pleadings or, in the Alternative, a Protective Order, as well as certain portions of
its Opposition that reference those exhibits (Dkt. 368 & 369). These exhibits and portions of the
brief contain material Plaintiff or a third-party has 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 370 Filed 08/31/23 Page 2 of 2 PageID# 5935
Dated: August 31, 2023
Respectfully submitted,
/s/ Craig C. Reilly
Craig C. Reilly (VSB # 20942)
THE LAW OFFICE OF
CRAIG C. REILLY, ESQ.
209 Madison Street
Alexandria, VA 22314
Telephone: (703) 549-5354
Facsimile: (703) 549-5355
craig.reilly@ccreillylaw.com
Eric Mahr (pro hac vice)
Andrew Ewalt (pro hac vice)
Julie Elmer (pro hac vice)
Lauren Kaplin (pro hac vice)
Jeanette Bayoumi (pro hac vice)
Claire Leonard (pro hac vice)
Sara Salem (pro hac vice)
Tyler Garrett (VSB # 94759)
FRESHFIELDS BRUCKHAUS
DERINGER US LLP
700 13th Street, NW, 10th Floor
Washington, DC 20005
Telephone: (202) 777-4500
Facsimile: (202) 777-4555
eric.mahr@freshfields.com
Counsel for Defendant Google LLC
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