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Berry v. Desert Palace, Inc., 2:17-cv-00019-GMN-PAL-APG-BNW. (2019)

Court: District Court, D. Nevada Number: infdco20191008r26 Visitors: 6
Filed: Oct. 01, 2019
Latest Update: Oct. 01, 2019
Summary: STIPULATION AND REQUEST FOR AN ORDER REGARDING PLAINTIFFS' SUBMISSION OF A REPLACEMENT BRIEF FOR THEIR SUPPLEMENTAL BRIEFING IN SUPPORT OF THEIR OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT BASED ON NEWLY PRODUCED DOCUMENTS [ECF NO. 136] ANDREW P. GORDON , District Judge . IT IS HEREBY STIPULATED AND AGREED among Plaintiffs WILLIAM J. BERRY, JR., CYNTHIA FALLS, AND SHANE KAUFMANN ("Plaintiffs") and Defendant DESERT PALACE, INC., d/b/a CAESARS PALACE ("Defendant"), that Plaintiffs b
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STIPULATION AND REQUEST FOR AN ORDER REGARDING PLAINTIFFS' SUBMISSION OF A REPLACEMENT BRIEF FOR THEIR SUPPLEMENTAL BRIEFING IN SUPPORT OF THEIR OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT BASED ON NEWLY PRODUCED DOCUMENTS [ECF NO. 136]

IT IS HEREBY STIPULATED AND AGREED among Plaintiffs WILLIAM J. BERRY, JR., CYNTHIA FALLS, AND SHANE KAUFMANN ("Plaintiffs") and Defendant DESERT PALACE, INC., d/b/a CAESARS PALACE ("Defendant"), that Plaintiffs be permitted to file a replacement to ECF No. 136, which is "Plaintiffs' Supplemental Briefing In Support of Their Opposition to Defendant's Motion for Summary Judgment Based on Newly Produced Documents." ECF No. 136. This replacement is requested because in filing their original supplemental brief on August 22, 2019, Plaintiffs incorrectly sought leave to file Exhibit 61 (Emails) and Exhibit 62 (Janiga's 2014 Tabulations) under seal. This new replacement supplemental briefing includes all of the exhibits properly categorized and properly redacted pursuant to the agreement between counsel with respect to sensitive and/or proprietary information.

The parties respectfully make this request pursuant to the Protective Order Regarding Confidential Discovery Materials [ECF No. 43], and submit that good cause exists for these minimal redactions in order to protect private, confidential, or proprietary information about Caesars Palace employees. By agreement, the redactions found in the replacement exhibits are limited to Caesars employees' personal phone numbers and the previously redacted (by Caesars) customer information.

MAIER GUTIERREZ & ASSOCIATES AKIN GUMP STRAUSS HAUER FELD LLP /s/ Danielle J. Barraza /s/ Esther G. Lander KATHLEEN J. ENGLAND ESTHER G. LANDER (pro hac vice) Nevada Bar No. 206 1333 New Hampshire Avenue, NW GILBERT & ENGLAND LAW FIRM Washington, DC 20036-1564 610 South Ninth Street Las Vegas, Nevada 89101 PATRICK H. HICKS JASON R. MAIER Nevada Bar No. 4832 Nevada Bar No. 8557 LITTLER MENDELSON, P.C. DANIELLE J. BARRAZA 3960 Howard Hughes Parkway, Ste. 300 Nevada Bar No. 13822 Las Vegas, NV 89169 8816 Spanish Ridge Avenue Las Vegas, Nevada 89148 SANDRA KETNER, ESQ. Attorneys for Plaintiffs William J. Berry, Nevada Bar No. 8527 Jr., Cynthia Falls and Shane Kaufmann LITTLER MENDELSON, P.C. 200 S. Virginia Street, 8th Floor Reno, NV 89501 Attorneys for Defendant Desert Palace, Inc. d/b/a Caesars Palace

ORDER ORDER

IT IS SO ORDERED.

Source:  Leagle

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