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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW PLAINTIFFS NOTICE OF REQUEST TO
SAN FRANCISCO SEAL DOCUMENTS AND FILE
REDACTED VERSIONS
Case 2:14-cv-01523-GEB-AC Document 12 Filed 06/26/14 Page 2 of 3
1 Pursuant to Local Rules 140 and 141, Entercom California LLC (Entercom) hereby
2 submits its Request to Seal Documents and File Redacted Versions of the following documents
4 Preliminary Injunction (filed concurrently herewith) and requests that the Court authorize
6 1. Entercoms Complaint;
12 The Licensing Agreement at the heart of this dispute contains a confidentiality provision
13 regarding the specific provision of the Agreement itself and also requires each party maintain as
14 confidential financial information that it receives about the other. Each of these documents
15 contains excerpts of or reference to the contract as well as financial information and filing the
16 such documents publicly would violate the Licensing Agreements confidentiality provision.
17 Accordingly, Plaintiff respectfully requests that the Court grant Entercoms permission to file
18 redacted versions of the above referenced documents in the public docket and to have the
21 Agreement, Entercom submits that good cause exists to grant this request.
22 In accordance with Local Rule 140, Entercom will submit this Notice, Request to Seal,
23 Proposed Order, and redacted and unredacted versions of the documents sought to be sealed via
24 electronic mail to the Court Clerk upon filing of the Complaint. Entercom has given notice to
26 Agreement as well as to attorney Kevin Hughley, who has represented Williams in recent
27 negotiations. Entercom also intends to submit these documents to the Court via email as soon as
28 this matter is assigned to a judge.
MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW 1 PLAINTIFFS NOTICE OF REQUEST TO
SAN FRANCISCO SEAL DOCUMENTS AND FILE
REDACTED VERSIONS
Case 2:14-cv-01523-GEB-AC Document 12 Filed 06/26/14 Page 3 of 3
2
By /s/
3 Benjamin P. Smith
Christopher J. Banks
4 Dennis J. Sinclitico, Jr.
Attorneys for Plaintiff
5 ENTERCOM CALIFORNIA LLC
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8 DB1/ 79833024.1
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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW 2 PLAINTIFFS NOTICE OF REQUEST TO
SAN FRANCISCO SEAL DOCUMENTS AND FILE
REDACTED VERSIONS