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Sears v. Russell Road Food and Beverage, LLC

United States District Court, D. Nevada

October 31, 2019

EMILY SEARS, NAJOME COLON aka GIA MACOOL, RACHEL BERNSTEIN a/k/a RACHEL KOREN, LUCY PINDER and MARIANA DAVALOS, Plaintiffs,
v.
RUSSELL ROAD FOOD AND BEVERAGE, LLC d/b/a CRAZY HORSE III GENTLEMEN'S CLUB; and SN INVESTMENT PROPERTIES, LLC d/b/a CRAZY HORSE III GENTLEMEN'S CLUB Defendant.

          BENDAVID LAW JEFFERY A. BENDAVID, ESQ. STEPHANIE J. SMITH, ESQ. Attorneys for Defendants

          ALVERSON TAYLOR & SANDERS KURT R. BONDS, ESQ. DAVID M. SEXTON, ESQ Attorneys for Plaintiffs

          STIPULATED PROTECTIVE ORDER

         Plaintiffs EMILY SEARS, NAJOME COLON aka GIA MACOOL, RACHEL BERNSTEIN a/k/a RACHEL KOREN, LUCY PINDER and MARIANA DAVALOS (collectively, “Plaintiffs”) and Defendants RUSSELL ROAD FOOD AND BEVERAGE, LLC D/B/A CRAZY HORSE III GENTLEMEN'S CLUB (“Russell Road”), and SN INVESTMENT PROPERTIES, LLC (“SN Investment”) (collectively, "Defendants")(the, Plaintiffs and Defendants may be collectively referred to herein as the, “Parties”) stipulate and agree as follows:

         WHEREAS, this action is a dispute involving claims by Plaintiffs' for what they allege to be Lanham Act violations, purported violations of Plaintiffs' right to publicity and negligence claims, which Defendants dispute in their entirety (“Action");

         WHEREAS, the Parties agree that discovery in this case may involve the production of confidential, proprietary and/or private information for which special protection from public disclosure may be warranted.

         WHEREFORE, the Parties hereby stipulate to and petition the court to enter the following Stipulated Protective Order.

         I. Definitions

         a. Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order.

         b. CONFIDENTIAL" Information or Items: information (regardless of how it is generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of Civil Procedure 26(c).

         c. Counsel (without qualifier): Outside Counsel of Record and In-House Counsel (as well as their support staff).

         d. Designating Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as "CONFIDENTIAL."

         e. Disclosure or Discovery Material: all items or information, regardless of the medium or manner in which it is generated, stored, or maintained (including, among other things, testimony, transcripts, and tangible things), that are produced or generated in disclosures or responses to discovery in the Action.

         f. Expert: a person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in the Action.

         g. House Counsel: attorneys who are employees of a Party to the Action. House Counsel does not include Outside Counsel of Record or any other outside counsel.

         h. Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to the Action.

         i. Outside Counsel of Record: attorneys who are not employees of a Party to the Action but are retained to represent or advise a party to the Action and have appeared in the Action on behalf of that Party or are affiliated with a law firm which has appeared on behalf of that Party.

         j. Party: any party to the Action, including all of its officers, directors, employees, consultants, Experts, and Outside Counsel of Record (and their support staffs).

         k. Producing Party: a Party or Non-Party that produces a Disclosure or Discovery Material in the Action.

         l. Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving data in any form or medium) and their employees and subcontractors.

         m. Protected Material: any Disclosure or Discovery Material that is designated as "CONFIDENTIAL" or “ATTORNEYS' EYES ONLY.”

         n. Receiving Party: a Party that receives Disclosure or Discovery ...


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