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CASE 0:17-cv-01212-RHK-TNL Document 3 Filed 04/18/17 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT


DISTRICT OF MINNESOTA

)
Paisley Park Enterprises, Inc. and ) Civil Action No. 17-cv-1212
Comerica Bank & Trust, N.A., as )
Personal Representative of the Estate of )
Prince Rogers Nelson, )
)
Plaintiffs, )
)
v. )
)
George Ian Boxill, )
)
Defendant. )
)

DEFENDANTS MOTION TO SEAL

In accordance with Local Rule 5.6(c), Defendant George Ian Boxill (Defendant) hereby

moves this Court for entry of an Order granting it permission for leave to file under seal the

Complaint, Summons and Exhibits A-G.

In support of this Motion, Defendant states that the Complaint, Summons and Exhibits A-

G purport to assert a Confidentiality Agreement, which provides, in the event of litigation, that

the Court file shall be sealed. (See Ex. A to Complaint at paragraph 6.) While Defendant

contends and asserts that the Confidentiality Agreement is not valid and controlling, out of an

abundance of caution, Defendant requests that the Court grant its motion to file these documents

under seal.

WHEREFORE, for the reasons set forth above, Defendant respectfully requests this

Court enter its Order allowing the Complaint, Summons and Exhibits A-G to be filed under seal

and for such other relief as the Court deems proper.

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CASE 0:17-cv-01212-RHK-TNL Document 3 Filed 04/18/17 Page 2 of 3

Dated: April 18, 2017 By: s/Anthony R. Zeuli


Anthony R. Zeuli (MN 274884)
Brent Routman (MN 265135)
Paige S. Stradley (MN 393432)
Merchant & Gould P.C.
3200 IDS Center
80 South 8th Street
Minneapolis, MN 55402
Phone: 612.332.5300
Email: tzeuli@merchantgould.com
Email: broutman@merchantgould.com
Email: pstradley@merchantgould.com

Christopher Brown (Pro Hac Vice to be Filed)


Brown & Rosen LLC
100 State Street
Boston, MA 02109
Phone: 617.728.9111
Email: cbrown@brownrosen.com

Attorneys for Defendant

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CASE 0:17-cv-01212-RHK-TNL Document 3 Filed 04/18/17 Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on April 18, 2017, a true and correct copy of the foregoing was

filed electronically and served by e-mail upon any party unable to accept electronic filing. Notice

of this filing will be sent by e-mail to all parties by operation of the Courts electronic filing

system. Parties may access this filing through the Courts CM/ECF system.

/s/ Anthony R. Zeuli


Anthony R. Zeuli