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23 Pursuant to Local Rules 140 and 141, Entercom California LLC (Entercom) hereby
24 submits its Request to Seal Documents and File Redacted Versions of the following documents
26 Preliminary Injunction (filed concurrently herewith) and requests that the Court authorize
27 Entercom to redact portions (1) Entercoms First Amended Complaint and (2) Entercoms
28 Amended Notice of Motion, Motion and Application for Temporary Restraining Order; and Order
MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
PLTFS NOTICE OF REQUEST TO SEAL
SAN FRANCISCO
1
DB1/ 79871392.1 Case No. 2:14-CV-01523 GEB AC
Case 2:14-cv-01523-GEB-AC Document 18 Filed 06/27/14 Page 2 of 2
1 to Show Cause re: Preliminary Injunction; Memorandum of Points and Authorities in Support
2 Thereof.
3 The Licensing Agreement at the heart of this dispute contains a confidentiality provision
4 regarding the specific provision of the Agreement itself and also requires each party maintain as
5 confidential financial information that it receives about the other. Both of these documents
6 contains excerpts of or reference to the contract as well as financial information and filing the
7 such documents publicly would violate the Licensing Agreements confidentiality provision.
8 Accordingly, Plaintiff respectfully requests that the Court grant Entercoms permission to file
9 redacted versions of the above referenced documents in the public docket and to have the
10 unredacted versions of these documents filed under seal.
12 Agreement, Entercom submits that good cause exists to grant this request.
13 In accordance with Local Rule 140, Entercom will submit this Notice, Request to Seal,
14 Proposed Order, and redacted and unredacted versions of the documents sought to be sealed via
15 electronic mail to the Courts Clerk. Entercom will provide notice of this Request to Seal to
16 Defendant Williams Broadcasting Incorporated (Williams) via attorney Kevin Hughley, who
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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
PLTFS NOTICE OF REQUEST TO SEAL
SAN FRANCISCO
2
DB1/ 79871392.1 Case No. 2:14-CV-01523 GEB AC