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Case 2:14-cv-01523-GEB-AC Document 18 Filed 06/27/14 Page 1 of 2

1 MORGAN, LEWIS & BOCKIUS LLP


BENJAMIN P. SMITH, State Bar No. 197551
2 CHRISTOPHER J. BANKS, State Bar No. 218779
DENNIS J. SINCLITICO, JR., State Bar No. 240260
3 One Market, Spear Street Tower
San Francisco, CA 94105-1126
4 Tel: 415.442.1000; Fax: 415.442.1001
bpsmith@morganlewis.com
5 cbanks@morganlewis.com
dsinclitico@morganlewis.com
6
Attorneys for Plaintiff
7 ENTERCOM CALIFORNIA LLC
8

9 UNITED STATES DISTRICT COURT

10 EASTERN DISTRICT OF CALIFORNIA

11

12 ENTERCOM CALIFORNIA LLC (F/K/A Case No. 2:14-cv-01523 GEB AC


ENTERCOM SACRAMENTO, LLC),
13 PLAINTIFFS NOTICE OF REQUEST
Plaintiff, TO SEAL DOCUMENTS AND FILE
14 REDACTED VERSIONS OF (1) FIRST
vs. AMENDED COMPLAINT AND (2)
15 AMENDED NOTICE OF MOTION,
WILLIAMS BROADCASTING MOTION AND APPLICATION FOR
16 INCORPORATED, TEMPORARY RESTRAINING
ORDER; AND ORDER TO SHOW
17 Defendant. CAUSE RE: PRELIMINARY
INJUNCTION; MEMORANDUM OF
18 POINTS AND AUTHORITIES IN
SUPPORT THEREOF
19
20 Date of Filing: June 26, 2014
Trial Date: Not Set
21

22

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

25 containing confidential business information submitted in support of Plaintiffs Application for

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.

11 In light of the contractual requirement to maintain the confidentiality of the License

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

17 has represented Williams in recent negotiations.

18

19 Dated: June 27, 2014 MORGAN, LEWIS & BOCKIUS LLP


20 By /s/ Benjamin P. Smith
Benjamin P. Smith
21
Attorneys for Plaintiff
22 ENTERCOM CALIFORNIA LLC
23

24

25

26

27
28
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