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Williams Broadcasting 11

This document is a proposed temporary restraining order and order to show cause regarding a preliminary injunction filed by Entercom California LLC against Williams Broadcasting Incorporated. It orders Williams Broadcasting to not license or provide the "Rob, Arnie & Dawn Show" to any other party in the Sacramento area besides Entercom. It also requires both parties to continue performing under their current programming agreement and orders the preservation of relevant evidence. A hearing date is set for Williams Broadcasting to show cause why a preliminary injunction should not be issued.

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Ethan Gates
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205 views3 pages

Williams Broadcasting 11

This document is a proposed temporary restraining order and order to show cause regarding a preliminary injunction filed by Entercom California LLC against Williams Broadcasting Incorporated. It orders Williams Broadcasting to not license or provide the "Rob, Arnie & Dawn Show" to any other party in the Sacramento area besides Entercom. It also requires both parties to continue performing under their current programming agreement and orders the preservation of relevant evidence. A hearing date is set for Williams Broadcasting to show cause why a preliminary injunction should not be issued.

Uploaded by

Ethan Gates
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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Case 2:14-cv-01523-GEB-AC Document 10 Filed 06/26/14 Page 1 of 3

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
5
Attorneys for Plaintiff
6 ENTERCOM CALIFORNIA LLC
7

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 [PROPOSED] TEMPORARY
Plaintiff, RESTRAINING ORDER AND ORDER
14 TO SHOW CAUSE RE: PRELIMINARY
vs. INJUNCTION
15
WILLIAMS BROADCASTING
16 INCORPORATED,

17 Defendant.

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW 1 [PROPOSED] TEMPORARY RESTRAINING ORDER
SAN FRANCISCO AND ORDER TO SHOW CAUSE RE:
PRELIMINARY INJUNCTION
Case 2:14-cv-01523-GEB-AC Document 10 Filed 06/26/14 Page 2 of 3

1 Upon consideration of Plaintiff Entercom California LLC (Entercom) Application for

2 Temporary Restraining Order and Order to Show Cause, the Memorandum of Points and

3 Authorities and declarations filed therewith, the Complaint, and on hearing oral argument, and it

4 appearing to the satisfaction of the Court that good cause exists:

5 IT IS HEREBY ORDERED THAT: Pending the preliminary injunction hearing,

6 Defendant Williams Broadcasting Incorporated and all of its agents, servants, employees and all

7 persons acting in concert or on its behalf including, but not limited to, Rob Williams, Arnie States

8 and Dawn Litz (a/k/a Dawn Rossi), (Williams) are prohibited and enjoined from:

9 Licensing the Rob, Arnie & Dawn Show (the Show). Licensing, offering, selling,
10 performing, broadcasting or otherwise providing the right to broadcast the Show or any other

11 radio program involving Mr. Williams, Mr. States and/or Ms. Litz in the terrestrial Sacramento

12 area to any party other than Entercom or otherwise breaching Section 25 of the 2005 Program

13 Agreement. Both parties shall continue to perform under the current Programming Agreement.

14 Preservation of Evidence. Destroying or otherwise failing to preserve all records,

15 computer files, electronic data files, e-mails, computer back-up files, computer hardware and all

16 other records, whether electronic, paper or otherwise, created by or for one or more of the

17 Defendants or in their possession, or control, that are likely to lead to the discovery of admissible

18 evidence regarding or pertaining to the claims alleged by Entercom in this action or any defense

19 thereto.
20 Entercom need not post security to pay the costs and damages, if any, sustained by

21 Williams should the Court find Williams to have been wrongfully enjoined or restrained.

22 IT IS FURTHER ORDERED THAT the parties shall return to this Court for hearing on

23 _______________, 2014, at ____a.m., or as soon thereafter as Williams Broadcasting Inc.

24 (Williams) counsel may be heard to show cause why a Preliminary Injunction should not issue

25 to restrain it from further engaging in the wrongful conduct complained of and further preserve

26 the status quo as provided in the Courts Temporary Restraining Order pending adjudication of

27 this matter.
28 Entercom shall file and serve its moving papers in support of its Application for an Order
MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW 2 [PROPOSED] TEMPORARY RESTRAINING ORDER
SAN FRANCISCO AND ORDER TO SHOW CAUSE RE:
PRELIMINARY INJUNCTION
Case 2:14-cv-01523-GEB-AC Document 10 Filed 06/26/14 Page 3 of 3

1 to Show Cause Re: Preliminary Injunction no later than _______________, 2014; any opposition

2 thereto shall be filed no later than ______________, 2014; any reply thereto shall be filed no later

3 than ____________, 2010. All papers shall be served by hand or by overnight delivery.

5 Dated: June ___, 2014


____________________________________
6
The Honorable
7 United States District Judge for the Eastern
District of California
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10 DB1/ 79841942.1

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW 3 [PROPOSED] TEMPORARY RESTRAINING ORDER
SAN FRANCISCO AND ORDER TO SHOW CAUSE RE:
PRELIMINARY INJUNCTION

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