`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MAINE
`
` Case No. 1:19-cv-00410-NT
`
`
`JOINT MOTION FOR ENTRY OF
`STIPULATED FINAL JUDGMENT AND
`ORDER FOR DECLARATORY AND
`PERMANENT INJUNCTIVE RELIEF
`
`
`
`COMCAST OF MAINE/NEW HAMPSHIRE,
`INC.; A&E TELEVISION NETWORKS,
`LLC; C-SPAN; CBS CORP.; DISCOVERY,
`INC.; DISNEY ENTERPRISES, INC.; FOX
`CABLE NETWORK SERVICES, LLC;
`NBCUNIVERSAL MEDIA, LLC; NEW
`ENGLAND SPORTS NETWORK, LP; and
`VIACOM INC.,
`
`Plaintiffs,
`
` v.
`
`JANET MILLS, in her official capacity as the
`Governor of Maine; AARON FREY, in his
`official capacity as the Attorney General of
`Maine; the CITY OF BATH, MAINE; the
`TOWN OF BERWICK, MAINE; the TOWN
`OF BOWDOIN, MAINE; the TOWN OF
`BOWDOINHAM, MAINE; the TOWN OF
`BRUNSWICK, MAINE; the TOWN OF
`DURHAM, MAINE; the TOWN OF ELIOT,
`MAINE; the TOWN OF FREEPORT,
`MAINE; the TOWN OF HARPSWELL,
`MAINE; the TOWN OF KITTERY, MAINE;
`the TOWN OF PHIPPSBURG, MAINE; the
`TOWN OF SOUTH BERWICK, MAINE; the
`TOWN OF TOPSHAM, MAINE; the TOWN
`OF WEST BATH, MAINE; and the TOWN
`OF WOOLWICH, MAINE;
`
`Defendants.
`
`
`
`
`
`Case 1:19-cv-00410-NT Document 108 Filed 04/23/21 Page 2 of 4 PageID #: 978
`
`
`
`Plaintiffs Comcast of Maine/New Hampshire, Inc., A&E Television Networks, LLC, C-
`
`SPAN, CBS Corp., Discovery, Inc., Disney Enterprises, Inc., Fox Cable Network Services, LLC,
`
`NBCUniversal Media, LLC, New England Sports Network, LP, and Viacom Inc. (hereafter
`
`“Plaintiffs”), and Defendants Janet Mills, in her official capacity as the Governor of Maine, and
`
`Aaron Frey, in his official capacity as the Attorney General of Maine1 (hereafter “Defendants”),
`
`hereby respectfully move this Court to approve and enter the attached proposed Stipulated Final
`
`Judgment and Order for Declaratory and Permanent Injunctive Relief, providing for declaratory
`
`and permanent injunctive relief in settlement of the Complaint, which alleges that H.P. 606 –
`
`L.D. 832, 129th Leg., Pub. Law, ch. 308 (Me. 2019), titled “An Act to Expand Options for
`
`Consumers of Cable Television in Purchasing Individual Channels and Programs,” is preempted
`
`by federal law and violates the First Amendment to the U.S. Constitution.
`
`IT IS SO MOVED this 23rd day of April, 2021.
`
`
`
`
`
`
`
`/s/ Joshua A. Tardy
`Joshua A. Tardy
`Joshua A. Randlett
`RUDMAN WINCHELL
`84 Harlow Street
`P.O. Box 1401
`Bangor, ME 1401
`jtardy@rudmanwinchell.com
`jrandlett@rudmanwinchell.com
`
`Attorneys for Plaintiffs
`
`Matthew A. Brill*
`Matthew T. Murchison*
`LATHAM & WATKINS LLP
`555 Eleventh Street, NW, Suite 1000
`Washington, D.C. 20004-1304
`matthew.brill@lw.com
`matthew.murchison@lw.com
`
`
`1 The remaining Defendants were dismissed pursuant to a joint stipulation. Dkt. 84.
`1
`
`
`
`Case 1:19-cv-00410-NT Document 108 Filed 04/23/21 Page 3 of 4 PageID #: 979
`
`
`
`
`
`
`
`
`
`
`Attorneys for Plaintiffs
`
`David P. Murray*
`Michael D. Hurwitz*
`WILLKIE FARR & GALLAGHER LLP
`1875 K Street, N.W.
`Washington, DC 20006-1238
`dmurray@willkie.com
`mhurwitz@willkie.com
`
`Attorneys for Plaintiffs Comcast of
`Maine/New Hampshire, Inc. and
`NBCUniversal Media, LLC
`
`*pro hac vice
`
`IT IS SO MOVED this 23rd day of April, 2021.
`
`
`
`
`Aaron M. Frey
`Attorney General
`
`/s/ Christopher C. Taub
`Christopher C. Taub
`Chief Deputy Attorney General
`Bar Number 65217
`Six State House Station
`Augusta, ME 04333-0006
`(207) 626-8800
`
`Attorneys for Defendants
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`2
`
`
`
`Case 1:19-cv-00410-NT Document 108 Filed 04/23/21 Page 4 of 4 PageID #: 980
`
`CERTIFICATE OF SERVICE
`I hereby certify that on this date, I electronically filed the foregoing document entitled
`
`Joint Motion for Entry of Stipulated Final Judgment and Order for Declaratory and Permanent
`
`Injunctive Relief via the Court’s CM/ECF system, which will serve a copy of same upon all
`
`counsel of record.
`
`DATED: April 23, 2021
`
`
`
`/s/ Christopher C. Taub
`Christopher C. Taub
`
`
`
`3
`
`
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