United States District Court, D. Nevada
EMILY SEARS, NAJOME COLON aka GIA MACOOL, RACHEL BERNSTEIN a/k/a RACHEL KOREN, LUCY PINDER and MARIANA DAVALOS, Plaintiffs,
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
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:
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
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.
the Parties hereby stipulate to and petition the court to
enter the following Stipulated Protective Order.
Challenging Party: a Party or Non-Party that challenges the
designation of information or items under this Order.
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).
Counsel (without qualifier): Outside Counsel of Record and
In-House Counsel (as well as their support staff).
Designating Party: a Party or Non-Party that designates
information or items that it produces in disclosures or in
responses to discovery as "CONFIDENTIAL."
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.
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.
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.
Non-Party: any natural person, partnership, corporation,
association, or other legal entity not named as a Party to
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.
Party: any party to the Action, including all of its
officers, directors, employees, consultants, Experts, and
Outside Counsel of Record (and their support staffs).
Producing Party: a Party or Non-Party that produces a
Disclosure or Discovery Material in the Action.
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.
Protected Material: any Disclosure or Discovery Material that
is designated as "CONFIDENTIAL" or
“ATTORNEYS' EYES ONLY.”
Receiving Party: a Party that receives Disclosure or