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
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Attorneys for Plaintiff
6 ENTERCOM CALIFORNIA LLC
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9 UNITED STATES DISTRICT COURT
10 EASTERN DISTRICT OF CALIFORNIA
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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
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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
____________________________________
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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
