Falls et al v. Desert Palace, Inc

Filing 123

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)

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Case 2:17-cv-00019-GMN-BNW Document 121 Filed 06/21/19 Page 1 of 3 1 2 3 4 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 5 6 7 8 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 9 10 Attorneys for Defendant DESERT PALACE, INC. d/b/a CAESARS PALACE 11 12 UNITED STATES DISTRICT COURT 13 DISTRICT OF NEVADA 14 15 16 WILLIAM J. BERRY, JR., CYNTHIA FALLS, and SHANE KAUFMANN, Plaintiff(s), 17 18 STIPULATION TO EXTEND DEADLINE TO SUBMIT REDACTED EXHIBITS vs. 19 Case No. 2:17-cv-00019-GMN-PAL DESERT PALACE, INC., d/b/a CAESARS PALACE, DOES I through x, et al. (First Request) 20 Defendant(s). 21 22 By Order dated June 17, 2019 (ECF No. 120), Magistrate Judge Weksler denied without 23 prejudice plaintiffs’ Motion for Leave to File Under Seal Appendix 3 of Exhibits in Support of 24 Opposition to Motion for Summary Judgment (ECF No. 105). The Order instructed plaintiffs to file 25 their renewed motion on or before June 21, 2019, or plaintiffs’ exhibits will be unsealed. 26 As the proponent of the confidential nature of information contained in plaintiffs’ exhibits, 27 such as the identities of Caesars’ high-limit customers which Caesars considers highly confidential 28 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 1 order to demonstrate a compelling need for the redaction of such information from plaintiffs’ 2 exhibits. In this regard, Caesars intends to provide plaintiffs with proposed redacted exhibits for 3 plaintiffs’ consideration. However, the exhibits are numerous (requiring the review of plaintiffs’ 4 Exhibits 1, 3, 17, 21, 22, 23, 24, 26, 30, 39, 40, 41, 43, 44, 45, 49, 53, 55 and 56 totaling over 300 5 pages) and redaction will be time consuming. Nevertheless, the parties believe that over the next 6 week and a half, they will be able to reach an agreement regarding appropriate information to be 7 redacted from the exhibits (such as customer identities). Upon reaching such agreement, Caesars 8 desires to re-file the exhibits with the appropriate redactions and demonstrate to the Court the 9 compelling need to allow such redactions. Therefore, the parties request that the Court extend the 10 deadline to seek renewed protection of information contained in plaintiffs’ Appendix 3 of Exhibits in 11 Support of Opposition to Motion for Summary Judgment by ten (10) days. 12 IT IS HEREBY STIPULATED AND AGREED by and between Plaintiffs WILLIAM J. 13 BERRY, JR., CYNTHIA FALLS, and SHANE KAUFMANN and Defendant DESERT PALACE, 14 INC. d/b/a CAESARS PALACE, by and through their respective counsel of record, that the deadline 15 to seek renewed protection for information contained in plaintiffs’ Appendix 3 of Exhibits in 16 Support of Opposition to Motion for Summary Judgment be extended by ten (10) days up to and 17 including July 1, 2019. 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 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 2. Case 2:17-cv-00019-GMN-BNW Document 121 Filed 06/21/19 Page 3 of 3 1 This is the parties’ first stipulation to extend the deadline to seek renewed protection of 2 information contained in Appendix 3 of Exhibits in Support of Opposition to Motion for Summary 3 Judgment. This stipulation is made in good faith and for the parties to work together in order to 4 reach an agreement regarding redaction to be presented to the Court. This stipulation is not for the 5 purpose of causing any undue delay, and the parties agree that good cause therefore exists for the 6 extension. 7 Dated: June 21, 2019 Dated: June 21, 2019 8 9 10 11 12 13 14 15 /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 _____ /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 16 ORDER 17 IT IS SO ORDERED. 18 19 20 UNITED STATES MAGISTRATE JUDGE 21 Dated this 25th day of June, 2019. 22 23 24 25 26 27 28 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 3. __

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