Falls et al v. Desert Palace, Inc
Filing
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ORDER Granting 121 First Stipulation to Extend Deadline to Submit Redacted Exhibits. Deadline: 7/1/2019. Signed by Magistrate Judge Brenda Weksler on 6/25/2019. (Copies have been distributed pursuant to the NEF - SLD)
Case 2:17-cv-00019-GMN-BNW Document 121 Filed 06/21/19 Page 1 of 3
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PATRICK H. HICKS, ESQ., Bar # 4632
LITTLER MENDELSON, P.C.
3960 Howard Hughes Parkway
Suite 300
Las Vegas, NV 89169-5937
Telephone: 702.862.8800
Fax No.:
702.862.8811
Email: phicks@littler.com
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ESTHER G. LANDER (DC Bar No. 461316)
Admitted pro hac vice
AKIN GUMP STRAUSS HAUER & FELD LLP
2001 K Street, N.W.
Washington, D.C. 20006
Telephone: (202) 887-4000
Email: elander@akingump.com
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Attorneys for Defendant
DESERT PALACE, INC.
d/b/a CAESARS PALACE
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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WILLIAM J. BERRY, JR., CYNTHIA
FALLS, and SHANE KAUFMANN,
Plaintiff(s),
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STIPULATION TO EXTEND
DEADLINE TO SUBMIT REDACTED
EXHIBITS
vs.
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Case No. 2:17-cv-00019-GMN-PAL
DESERT PALACE, INC., d/b/a CAESARS
PALACE, DOES I through x, et al.
(First Request)
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Defendant(s).
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By Order dated June 17, 2019 (ECF No. 120), Magistrate Judge Weksler denied without
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prejudice plaintiffs’ Motion for Leave to File Under Seal Appendix 3 of Exhibits in Support of
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Opposition to Motion for Summary Judgment (ECF No. 105). The Order instructed plaintiffs to file
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their renewed motion on or before June 21, 2019, or plaintiffs’ exhibits will be unsealed.
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As the proponent of the confidential nature of information contained in plaintiffs’ exhibits,
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such as the identities of Caesars’ high-limit customers which Caesars considers highly confidential
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and proprietary business information, Caesars’ counsel desires to work with plaintiffs’ counsel in
LITTLE R MEND ELSO N, P .C .
ATTORNEYS AT LAW
3960 H oward Hughes Parkway
Suite 300
Las Vegas, NV 89169-5937
702.862.8800
FIRMWIDE:165089632.1 083558.1241
Case 2:17-cv-00019-GMN-BNW Document 121 Filed 06/21/19 Page 2 of 3
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order to demonstrate a compelling need for the redaction of such information from plaintiffs’
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exhibits. In this regard, Caesars intends to provide plaintiffs with proposed redacted exhibits for
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plaintiffs’ consideration. However, the exhibits are numerous (requiring the review of plaintiffs’
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Exhibits 1, 3, 17, 21, 22, 23, 24, 26, 30, 39, 40, 41, 43, 44, 45, 49, 53, 55 and 56 totaling over 300
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pages) and redaction will be time consuming. Nevertheless, the parties believe that over the next
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week and a half, they will be able to reach an agreement regarding appropriate information to be
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redacted from the exhibits (such as customer identities). Upon reaching such agreement, Caesars
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desires to re-file the exhibits with the appropriate redactions and demonstrate to the Court the
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compelling need to allow such redactions. Therefore, the parties request that the Court extend the
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deadline to seek renewed protection of information contained in plaintiffs’ Appendix 3 of Exhibits in
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Support of Opposition to Motion for Summary Judgment by ten (10) days.
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IT IS HEREBY STIPULATED AND AGREED by and between Plaintiffs WILLIAM J.
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BERRY, JR., CYNTHIA FALLS, and SHANE KAUFMANN and Defendant DESERT PALACE,
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INC. d/b/a CAESARS PALACE, by and through their respective counsel of record, that the deadline
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to seek renewed protection for information contained in plaintiffs’ Appendix 3 of Exhibits in
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Support of Opposition to Motion for Summary Judgment be extended by ten (10) days up to and
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including July 1, 2019.
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LITTLE R MEND ELSO N, P .C .
ATTORNEYS AT LAW
3960 H oward Hughes Parkway
Suite 300
Las Vegas, NV 89169-5937
702.862.8800
FIRMWIDE:165089632.1 083558.1241
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Case 2:17-cv-00019-GMN-BNW Document 121 Filed 06/21/19 Page 3 of 3
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This is the parties’ first stipulation to extend the deadline to seek renewed protection of
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information contained in Appendix 3 of Exhibits in Support of Opposition to Motion for Summary
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Judgment. This stipulation is made in good faith and for the parties to work together in order to
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reach an agreement regarding redaction to be presented to the Court. This stipulation is not for the
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purpose of causing any undue delay, and the parties agree that good cause therefore exists for the
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extension.
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Dated: June 21, 2019
Dated: June 21, 2019
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/s/ Kathleen J. England
KATHLEEN J. ENGLAND, ESQ.
Gilbert & England Law Firm
JASON R. MAIER
DANIELLE J. BARRAZA
Maier Gutierrez & Associates
Attorneys for Plaintiffs
William H. Berry Jr., Cynthia Falls, and
Shane Kaufmann
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/s/ Patrick H. Hicks
PATRICK H. HICKS, ESQ._
Littler Mendelson, P.C.
ESTHER G. LANDER
Akin Gump Strauss Hauer & Feld, LLP
Attorneys for Defendant
DESERT PALACE, INC.
dba CAESARS PALACE
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ORDER
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IT IS SO ORDERED.
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UNITED STATES MAGISTRATE JUDGE
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Dated this 25th day of June, 2019.
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LITTLE R MEND ELSO N, P .C .
ATTORNEYS AT LAW
3960 H oward Hughes Parkway
Suite 300
Las Vegas, NV 89169-5937
702.862.8800
FIRMWIDE:165089632.1 083558.1241
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