Grand Canyon Skywalk Development, LLC et al v. Steele et al

Filing 160

ORDER Granting 156 Motion to Seal 158 Exhibit. Signed by Magistrate Judge George Foley, Jr on 2/22/16. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:13-cv-00596-GWF Document 156 Filed 02/19/16 Page 1 of 3

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MARK G. TRATOS, ESQ.
Nevada Bar No. 1086
DONALD L. PRUNTY, ESQ.
Nevada Bar No. 8230
GREENBERG TRAURIG, LLP
3773 Howard Hughes Parkway
Suite 400 North
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]

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Counsel for Plaintiff

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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GREENBERG TRAURIG, LLP
3773 Howard Hughes Parkway, Suite 400 North
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: [phone]

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GRAND CANYON SKYWALK
DEVELOPMENT, LLC, a Nevada
limited liability company; DY TRUST
DATED JUNE 3, 2013, a Nevada
Trust; THEODORE (TED) R.
QUASULA, an individual;

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Plaintiff,

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v.

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DAVID JOHN CIESLAK, an
individual; NICHOLAS PETER
“CHIP’ SCUTARI, an individual;
SCUTARI & CIESLAK PUBLIC
RELATIONS, INC., an Arizona
corporation.

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Case No.: 2:13-cv-00596-RCJ-GWF

PLAINTIFF’S MOTION TO FILE UNDER
SEAL EXHIBIT 1 TO PLAINTIFF’S
REPLY IN SUPPORT OF MOTION FOR
LEAVE TO FILE FIRST AMENDED
COMPLAINT

Defendant.
and related Third-Party Complaint

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Plaintiffs, Grand Canyon Skywalk Development, LLC (“GCSD”), DY TRUST DATED

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JUNE 3, 2013, (“Jin”), and Ted Quasula (“Quasula”) (collectively “Plaintiffs”) by and through its

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undersigned counsel, the law firm of Greenberg Traurig, LLP, hereby files their Motion to File under

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Seal Exhibit 1 to Plaintiffs’ Reply in Support of their Motion for Leave to File First Amended

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Complaint (“Reply”).

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Case 2:13-cv-00596-GWF Document 156 Filed 02/19/16 Page 2 of 3

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A stipulated protective order has been entered in this case [Doc. No.74]. Pursuant to the

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terms of the protective order, information disclosed in documents produced by a party deemed

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confidential shall be governed by the protective order and marked with an appropriate legend of

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“Confidential” or “Confidential-Attorneys’ Eyes Only”.

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Exhibit 1 to Plaintiffs’ Reply, being filed concurrently herewith, contains quoted statements

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derived from documents which have been produced and designated by Defendants as Confidential or

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Confidential-Attorneys’ Eyes Only. Public disclosure of the information contained in Exhibit 1 to

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the Reply would waive the confidential nature of the information.

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GREENBERG TRAURIG, LLP
3773 Howard Hughes Parkway, Suite 400 North
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: [phone]

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WHEREFORE, Plaintiffs respectfully requests that the Court grant them leave to file Exhibit
1 to their Reply in support of their Motion for Leave to File First Amended Complaint under seal.

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DATED: February 19, 2016.

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GREENBERG TRAURIG, LLP
/s/ Mark G. Tratos
Mark G. Tratos (Nev. Bar No. 1086)
Donald L. Prunty (Nev. Bar No. 8230)
GREENBERG TRAURIG, LLP
3773 Howard Hughes Parkway, Suite 400N
Las Vegas, Nevada 89169
Counsel for Plaintiffs

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ORDER

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Having read and considered Plaintiffs’ Motion to File Under Seal Exhibit 1 to Plaintiffs’
Reply in Support of their Motion for Leave to File First Amended Complaint, and for good cause
shown,
February
22nd
It is so ORDERED this ______ day of ____________, 2016 that to Plaintiffs’ Reply in
Support of their Motion for Leave to File First Amended Complaint, be filed under seal.

_____________________________________
UNITED STATES MAGISTRATE JUDGE
UNITED STATES DISTRICT JUDGE
DATED: February 22, 2016
DATED: _____________________________

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Case 2:13-cv-00596-GWF Document 156 Filed 02/19/16 Page 3 of 3

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CERTIFICATE OF SERVICE

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I hereby certify that on February 19, 2016, I served PLAINTIFF’S MOTION TO FILE

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UNDER SEAL EXHIBIT 1 TO PLAINTIFF’S REPLY IN SUPPORT OF MOTION FOR

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LEAVE TO FILE FIRST AMENDED COMPLAINT via the court’s CM/ECF electronic service

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to all registered parties:

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GREENBERG TRAURIG, LLP
3773 Howard Hughes Parkway, Suite 400 North
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: [phone]

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Nicholas M. Wieczorek
Sunethra Muralidhara
MORRIS POLICH & PURDY, LLP
500 South Rancho Drive, Suite 17
Las Vegas, NV 89106
Attorneys for Defendants David John Cieslak,
Nicholas Peter “Chip” Scutari and
Scutari & Cieslak Public Relations, Inc.

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/s/ Cynthia Ney
An Employee of Greenberg Traurig, LLP

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