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United States Court of Appeals for the SEVENTH CIRCUIT ______ No. 11-2066 IN THE United States Court of Appeals FOR THE SEVENTH CIRCUIT _________________________ CHICAGO TRIBUNE COMPANY, Plaintiff-Appellee, v. UNIVERSITY OF ILLINOIS BOARD OF TRUSTEES, Defendant-Appellant. _________________________ Appeal from the United States District Court for the Northern District of Illinois, Eastern Division, No.10 C 568, the Hon. Joan B. Gottschall _________________________ BRIEF AMICI CURIAE OF THE REPORTERS COMMITTEE FOR FREEDOM OF THE PRESS, THE STUDENT PRESS LAW CENTER, ABC, INC., ADVANCE PUBLICATIONS, INC., AMERICAN SOCIETY OF NEWS EDITORS, THE ASSOCIATED PRESS, ASSOCIATION OF CAPITOL REPORTERS AND EDITORS, ATLANTIC MEDIA, INC., BLOOMBERG L.P., DOW JONES & COMPANY, INC., THE E.W. SCRIPPS COMPANY, FIRST AMENDMENT COALITION, GANNETT CO., INC., THE MCCLATCHY COMPANY, NATIONAL PRESS PHOTOGRAPHERS ASSOCIATION, NBCUNIVERSAL MEDIA, LLC, THE NEW YORK TIMES COMPANY, NEWSPAPER ASSOCIATION OF AMERICA, NEWSPAPER GUILD – CWA, THE NEWSWEEK/DAILY BEAST COMPANY LLC, NORTH JERSEY MEDIA GROUP INC., THE SEATTLE TIMES CO., AND SOCIETY OF PROFESSIONAL JOURNALISTS IN SUPPORT OF PLAINTIFF-APPELLEE URGING AFFIRMANCE _________________________ Counsel for amici curiae: Lucy A. Dalglish, Counsel of Record Frank D. LoMonte Mark R. Caramanica Student Press Law Center The Reporters Committee for Freedom of the Press 1101 Wilson Blvd., Suite 1100 1101 Wilson Blvd., Suite 1100 Arlington, VA 22209 Arlington, VA 22209 Telephone: (703) 807-1904 Telephone: (703) 807-2100 (*Additional amici counsel listed on pages following cover) *Additional amici counsel: John W. Zucker David M. Giles ABC, Inc. Vice President/Deputy General Counsel 77 W. 66th Street, 16th Floor The E.W. Scripps Company New York, NY 10023 312 Walnut St., Suite 2800 Cincinnati, OH 45202 Richard A. Bernstein Neil M. Rosenhouse Peter Scheer Sabin, Bermant & Gould LLP First Amendment Coalition 4 Times Square, 23rd Floor 534 4th St., Suite B New York, NY 10036 San Rafael, CA 94901 Counsel for Advance Publications, Inc. Barbara W. Wall Kevin M. Goldberg Vice President/Senior Fletcher, Heald & Hildreth, PLC Associate General Counsel 1300 N. 17th St., 11th Floor Gannett Co., Inc. Arlington, VA 22209 7950 Jones Branch Drive Counsel for American Society of News McLean, VA 22107 Editors and Association of Capitol Reporters and Editors Karole Morgan-Prager The McClatchy Company Karen Kaiser 2100 Q Street Associate General Counsel Sacramento, CA 95816 The Associated Press 450 W. 33rd Street Mickey H. Osterreicher New York, NY 10001 40 Wagon Wheel Drive East Amherst, NY 14051 Bruce L. Gottlieb Counsel for National Press Photographers General Counsel Association Atlantic Media, Inc. 600 New Hampshire Ave., NW Steve Chung Washington, DC 20037 NBCUniversal Media, LLC 30 Rockefeller Plaza Charles J. Glasser, Jr. Room 1008E Global Media Counsel New York, NY 10112 Bloomberg L.P. 731 Lexington Avenue David E. McCraw New York, NY 10022 V.P./Assistant General Counsel The New York Times Company Jason Conti 620 Eighth Avenue Gail Gove New York, NY 10018 1211 Avenue of the Americas, 7th Floor New York, NY 10036 Counsel for Dow Jones & Company, Inc. René P. Milam Vice President/General Counsel Newspaper Association of America 4401 Wilson Blvd., Suite 900 Arlington, VA 22203 Barbara L. Camens Barr & Camens 1025 Connecticut Ave., NW, Suite 712 Washington, DC 20036 Counsel for The Newspaper Guild – CWA Randy L. Shapiro The Newsweek/Daily Beast Company LLC 555 W. 18th St., 2nd Floor New York, NY 10011 Jennifer Borg General Counsel North Jersey Media Group Inc. 1 Garret Mountain Plaza P.O. Box 471 Woodland Park, NJ 07424 Bruce E. H. Johnson Davis Wright Tremaine LLP 1201 Third Ave., Suite 2200 Seattle, WA 98101 Counsel for The Seattle Times Co. Bruce W. Sanford Bruce D. Brown Laurie A. Babinski Baker & Hostetler LLP 1050 Connecticut Ave., NW, Suite 1100 Washington, DC 20036 Counsel for Society of Professional Journalists CIRCUIT RULE 26.1 DISCLOSURE STATEMENT Appellate Court No: 11-2066 Short Caption: Chicago Tribune Company v. Univ. of Illinois Bd. of Trustees To enable the judges to determine whether recusal is necessary or appropriate, an attorney for a non-governmental party or amicus curiae, or a private attorney representing a government party, must furnish a disclosure statement providing the following information in compliance with Circuit Rule 26.1 and Fed. R. App. P. 26.1. The Court prefers that the disclosure statement be filed immediately following docketing; but, the disclosure statement must be filed within 21 days of docketing or upon the filing of a motion, response, petition, or answer in this court, whichever occurs first. Attorneys are required to file an amended statement to reflect any material changes in the required information. The text of the statement must also be included in front of the table of contents of the party's main brief. Counsel is required to complete the entire statement and to use N/A for any information that is not applicable if this form is used. [ ] PLEASE CHECK HERE IF ANY INFORMATION ON THIS FORM IS NEW OR REVISED AND INDICATE WHICH INFORMATION IS NEW OR REVISED. (1) The full name of every party that the attorney represents in the case (if the party is a corporation, you must provide the corporate disclosure information required by Fed. R. App. P 26.1 by completing item #3): The Reporters Committee for Freedom of the Press (2) The names of all law firms whose partners or associates have appeared for the party in the case (including proceedings in the district court or before an administrative agency) or are expected to appear for the party in this court: N/A (3) If the party or amicus is a corporation: i) Identify all its parent corporations, if any; and N/A ii) list any publicly held company that owns 10% or more of the party’s or amicus’ stock: N/A Attorney's Signature: /s/ Lucy A. Dalglish Date: 8/16/2011 Attorney's Printed Name: Lucy A. Dalglish Please indicate if you are Counsel of Record for the above listed parties pursuant to Circuit Rule 3(d). Yes X No Address: 1101 Wilson Blvd., Suite 1100 Arlington, VA 22209 Phone Number: (703) 807-2100 Fax Number: (703) 807-2109 E-Mail Address: [email protected] rev. 01/08 AK CIRCUIT RULE 26.1 DISCLOSURE STATEMENT Appellate Court No: 11-2066 Short Caption: Chicago Tribune Company v. Univ. of Illinois Bd. of Trustees To enable the judges to determine whether recusal is necessary or appropriate, an attorney for a non-governmental party or amicus curiae, or a private attorney representing a government party, must furnish a disclosure statement providing the following information in compliance with Circuit Rule 26.1 and Fed. R. App. P. 26.1. The Court prefers that the disclosure statement be filed immediately following docketing; but, the disclosure statement must be filed within 21 days of docketing or upon the filing of a motion, response, petition, or answer in this court, whichever occurs first. Attorneys are required to file an amended statement to reflect any material changes in the required information. The text of the statement must also be included in front of the table of contents of the party's main brief. Counsel is required to complete the entire statement and to use N/A for any information that is not applicable if this form is used. [ ] PLEASE CHECK HERE IF ANY INFORMATION ON THIS FORM IS NEW OR REVISED AND INDICATE WHICH INFORMATION IS NEW OR REVISED. (1) The full name of every party that the attorney represents in the case (if the party is a corporation, you must provide the corporate disclosure information required by Fed. R. App. P 26.1 by completing item #3): The Reporters Committee for Freedom of the Press (2) The names of all law firms whose partners or associates have appeared for the party in the case (including proceedings in the district court or before an administrative agency) or are expected to appear for the party in this court: N/A (3) If the party or amicus is a corporation: i) Identify all its parent corporations, if any; and N/A ii) list any publicly held company that owns 10% or more of the party’s or amicus’ stock: N/A Attorney's Signature: /s/ Mark R. Caramanica Date: 8/16/2011 Attorney's Printed Name: Mark R. Caramanica Please indicate if you are Counsel of Record for the above listed parties pursuant to Circuit Rule 3(d). Yes No X Address: 1101 Wilson Blvd., Suite 1100 Arlington, VA 22209 Phone Number: (703) 807-2100 Fax Number: (703) 807-2109 E-Mail Address: [email protected] rev. 01/08 AK CIRCUIT RULE 26.1 DISCLOSURE STATEMENT Appellate Court No: 11-2066 Short Caption: Chicago Tribune Company v. Univ. of Illinois Bd. of Trustees To enable the judges to determine whether recusal is necessary or appropriate, an attorney for a non-governmental party or amicus curiae, or a private attorney representing a government party, must furnish a disclosure statement providing the following information in compliance with Circuit Rule 26.1 and Fed. R. App. P. 26.1. The Court prefers that the disclosure statement be filed immediately following docketing; but, the disclosure statement must be filed within 21 days of docketing or upon the filing of a motion, response, petition, or answer in this court, whichever occurs first. Attorneys are required to file an amended statement to reflect any material changes in the required information. The text of the statement must also be included in front of the table of contents of the party's main brief. Counsel is required to complete the entire statement and to use N/A for any information that is not applicable if this form is used. [ ] PLEASE CHECK HERE IF ANY INFORMATION ON THIS FORM IS NEW OR REVISED AND INDICATE WHICH INFORMATION IS NEW OR REVISED.
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