International Markets Live, Inc. v. IMONITIE et al, No. 2:2022cv01863 - Document 208 (D. Nev. 2023)

Court Description: ORDER granting ECF No. 204 Second Stipulated Joinder to Stipulated Protective Order Regarding Confidentiality. Signed by Magistrate Judge Brenda Weksler on 6/22/2023. (Copies have been distributed pursuant to the NEF - DRM)

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International Markets Live, Inc. v. IMONITIE et al Doc. 208 Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document208 204 Filed Filed06/22/23 06/21/23 Page Page11of of25 4 HOLLAND & HART LLP 9555 HILLWOOD DRIVE, 2ND FLOOR LAS VEGAS, NV 89134 1 P. Sterling Kerr, Esq. Nevada Bar No. 3978 2 George E. Robinson, Esq. Nevada Bar No. 9667 3 KERR SIMPSON ATTORNEYS AT LAW 2900 W. Horizon Ridge Parkway, Suite 200 4 Henderson, NV 89052 Phone: 702.451.2055 5 Fax: 702.451.2077 sterling@kerrsimpsonlaw.com 6 george@kerrsimpsonlaw.com 7 Lars K. Evensen, Esq. Nevada Bar No. 8061 8 Jenapher Lin, Esq. Nevada Bar No. 14233 9 HOLLAND & HART LLP 9555 Hillwood Drive, 2nd Floor 10 Las Vegas, NV 89134 Phone: 702.669.4600 11 Fax: 702.669.4650 lkevensen@hollandhart.com 12 jlin@hollandhart.com 13 Attorneys for Plaintiff 14 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 15 INTERNATIONAL MARKETS LIVE INC., a New York corporation dba IM MASTERY 16 ACADEMY, 17 Case No.: 2:22-cv-01863-GMN-BNW STIPULATION AND ORDER REGARDING JOINDER TO STIPULATED PROTECTIVE ORDER REGARDING CONFIDENTIALITY (SECOND) Plaintiff, 18 v. 19 DAVID IMONITIE an individual; SPELA SLUGA, an individual; DEVON ROESER, an 20 individual; IVAN TAPIA, an individual; NVISIONU, INC., a Delaware corporation; 21 ILYKIT, LLC, a Utah limited liability company, LUCAS LONGMIRE, an 22 individual; NATHAN SAMUEL, an individual; MICHAEL ZHOR, an individual; 23 IMRAN RICHIE, an individual; JUSTIN OWENS, an individual; PAULO 24 CAVALLERI, an individual; JOSE MIGUEL CONTREAS, an individual; BASS GRANT, 25 an individual; ANGELA CRUISHANK, an individual; JEFF CRUISHANK, an 26 individual; VINCE MURPHY, an individual; GARY MCSWEEN, an individual; 27 KATRINA WORGESS, an individual; LUIS RONALDO HARNANDEZ ARRIAGA, an 28 individual; STEPHANIA AYO, an individual; 1 Dockets.Justia.com Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document208 204 Filed Filed06/22/23 06/21/23 Page Page22of of25 4 1 SILVIA AYO, an individual; CATALINA VASQUEZ, an individual; MATHIAS 2 VASQUEZ, an individual; DOES 1 through 10, inclusive; and ROE CORPORATIONS I 3 through X, inclusive, 4 5 6 Defendants. AND ALL RELATED MATTERS. Plaintiff INTERNATIONAL MARKETS LIVE INC., dba IM MASTERY ACADEMY 7 8 (“IML” or “Plaintiff”), and Defendants DAVID IMONITIE, SPELA SLUGA, DEVON ROESER, 9 IVAN TAPIA, NVISIONU, INC., BASS GRANT, LUCAS LONGMIRE, VINCE MURPHY, 10 ILYKIT, LLC, ANGELA CRUICKSHANK, JEFF CRUICKSHANK, and JUSTIN OWENS HOLLAND & HART LLP 9555 HILLWOOD DRIVE, 2ND FLOOR LAS VEGAS, NV 89134 11 (collectively, as the “Parties”), by and through their respective undersigned counsel, hereby stipulate 12 and agree that the handling of confidential material by Defendants ANGELA CRUICKSHANK, 13 JEFF CRUICKSHANK, and JUSTIN OWENS in the above-captioned matter shall likewise be 14 governed by the provisions set forth in the Stipulated Protective Order regarding Confidentiality, 15 dated October 7, 2022, . . . 16 17 18 /// 19 20 21 /// 22 23 24 25 /// 26 27 28 /// 2 Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document208 204 Filed Filed06/22/23 06/21/23 Page Page33of of25 4 1 2 . . . a copy of which is attached hereto as Exhibit 1. 3 DATED this 21st day of June 2023. 4 HOLLAND & HART LLP SLIGHTING LAW 5 /s/ Lars K. Evensen Lars K. Evensen, Esq. Jenapher Lin, Esq. 9555 Hillwood Drive, 2nd Floor Las Vegas, NV 89134 /s/ Christopher Wellman Bradley S. Slighting, Esq. (NBN 10225) 1707 Village Center Cir., #100 Las Vegas, NV 89134 Telephone: (702) 232-2543 Email: brad@slightinglaw.com 6 7 8 9 HOLLAND & HART LLP 9555 HILLWOOD DRIVE, 2ND FLOOR LAS VEGAS, NV 89134 10 KERR SIMPSON ATTORNEYS AT LAW P. Sterling Kerr, Esq. George E. Robinson, Esq. 2900 W. Horizon Ridge Parkway, Suite 200 Henderson, NV 89052 Christopher Wellman (pro hac vice) California Bar No. 304700 WELLMAN & WARREN LLP 24411 Ridge Route, Suite 200 Laguna Hills, CA 92653 Tel: (949) 580-3737 cwellman@w-wlaw.com 11 Attorneys for Plaintiff/Counterdefendant International Markets Live, Inc. and 12 Counterdefendant Christopher Terry Attorneys for Defendants DAVID IMONITIE; SPELA SLUGA; DEVON ROESER; NVISIONU, INC., Bass Grant, Lucas Longmire, Vince Murphy 13 14 15 16 17 18 19 20 21 THOMPSON BURTON, PLLC SLIGHTING LAW /s/ Justin L. James Bradley S. Slighting, Esq. (NBN 10225) JON E. FIELD, ESQ. Nevada Bar No. 7700 One Franklin Park 6100 Tower Circle Suite 200 Franklin, Tennessee 37067 Tele: (615) 465-6000 Email: jfield@thompsonburton.com Justin L. James (pro hac vice) Utah Bar No. 15167 James Dodge Russell & Stephens PC 10 West Broadway, Suite 400 Salt Lake City, UT 84101 801.363.6363 jjames@jdrslaw.com Attorney for Defendant ILYKIT, LLC Attorneys for Defendants Ivan Tapia, Angela Cruickshank, Jeff Cruickshank, and Justin Owens 22 23 24 IT IS SO ORDERED: 25 26 UNITED STATES MAGISTRATE JUDGE 27 June 22, 2023 DATED: _____________________________ 28 3 Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document208 204 Filed Filed06/22/23 06/21/23 Page Page44of of25 4 1 CERTIFICATE OF SERVICE I hereby certify that on the 21st day of June 2023, a true and correct copy of the foregoing 2 3 STIPULATION AND ORDER REGARDING JOINDER TO STIPULATED PROTECTIVE 4 ORDER REGARDING CONFIDENTIALITY (SECOND) was served by the following 5 method(s): 6 7 8 Electronic: by submitting electronically for filing and/or service with the United States District Court, District of Nevada’s e-filing system and served on counsel electronically in accordance with the E-service list to the following email addresses: Bradley S. Slighting (10225) SLIGHTING LAW 1707 Village Center Cir, Ste 100 Las Vegas, NV 89134 Tel: (702) 840-3749 brad@slightinglaw.com Bradley S. Slighting (10225) SLIGHTING LAW 1707 Village Center Cir, Ste 100 Las Vegas, NV 89134 Tel: (702) 840-3749 brad@slightinglaw.com Christopher Wellman (pro hac vice) California Bar No. 304700 WELLMAN & WARREN LLP 24411 Ridge Route, Suite 200 Laguna Hills, CA 92653 Tel: (949) 580-3737 cwellman@w-wlaw.com Justin L. James (pro hac vice) Utah Bar No. 15167 James Dodge Russell & Stephens PC 10 West Broadway, Suite 400 Salt Lake City, UT 84101 801.363.6363 jjames@jdrslaw.com Attorneys for Defendants David Imonitie; Spela Sluga; Devon Roeser; Nvisionu, Inc., Bass Grant, Lucas Longmire, Vince Murphy Attorneys for Defendants Ivan Tapia, Angela Cruickshank, Jeff Cruickshank, and Justin Owens 21 Jon E. Field, Esq. THOMPSON BURTON, PLLC One Franklin Park 6100 Tower Circle Suite 200 Franklin, Tennessee 37067 Tele: (615) 465-6000 Email: jfield@thompsonburton.com Nathan Samuel Pro Se litigant 1874 Brooks Dr NW Atlanta, GA 30318 Email: Nathanmorehouse171@gmail.com Tel: 516.282.5246 22 Attorney for Defendant ILYKIT, LLC 9 10 11 HOLLAND & HART LLP 9555 HILLWOOD DRIVE, 2ND FLOOR LAS VEGAS, NV 89134 12 13 14 15 16 17 18 19 20 23 24 25 26 /s/ Brenda Schroeder An Employee of Holland & Hart LLP 27 28 4 ELECTRONICALLY SERVED 2:47204-1 PM Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW10/7/2022 Document Document 208 Filed Filed06/22/23 06/21/23 Page Page51ofof25 21 H OLLAND & H ART LLP 9555 H ILLWOOD DRIVE, 2 ND FLOOR LAS VEGAS, NV 89134 Electronically Filed 10/07/2022 2:46 PM 1 SPO P. Sterling Kerr, Esq. 2 Nevada Bar No. 3978 George E. Robinson, Esq. 3 Nevada Bar No. 9667 KERR SIMPSON ATTORNEYS AT LAW 4 2900 W. Horizon Ridge Parkway, Suite 200 Henderson, NV 89052 5 Phone: 702.451.2055 Fax: 702.451.2077 6 sterling@kerrsimpsonlaw.com george@kerrsimpsonlaw.com 7 Lars K. Evensen, Esq. 8 Nevada Bar No. 8061 Jenapher Lin, Esq. 9 Nevada Bar No. 14233 HOLLAND & HART LLP 10 9555 Hillwood Drive, 2nd Floor Las Vegas, NV 89134 11 Phone: 702.669.4600 Fax: 702.669.4650 12 lkevensen@hollandhart.com jlin@hollandhart.com 13 Attorneys for Plaintiff 14 DISTRICT COURT 15 CLARK COUNTY, NEVADA 16 INTERNATIONAL MARKETS LIVE INC., a New York corporation dba IM MASTERY 17 ACADEMY, 18 Case No. A-22-854783-B Dept. No. XVI STIPULATED PROTECTIVE ORDER REGARDING CONFIDENTIALITY Plaintiff, 19 v. 20 DAVID IMONITIE an individual; SPELA SLUGA, an individual; DEVON ROESER, an 21 individual; IVAN TAPIA, an individual; NVISIONU, INC., a Delaware corporation; 22 ILYKIT, LLC, a Utah limited liability company, 23 Defendants. 24 25 IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff 26 INTERNATIONAL MARKETS LIVE INC., dba IM MASTERY ACADEMY (“IML”), and 27 Defendants DAVID IMONITIE, SPELA SLUGA, DEVON ROESER, and NVISIONU, INC. 28 (“Defendants” and collectively, with IML, as the “Parties”), by and through their respective counsel 1 Case Number: A-22-854783-B Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document204-1 208 Filed Filed06/22/23 06/21/23 Page Page62ofof25 21 1 of record, that the handling of confidential material in these proceedings shall be governed by the 2 provisions set forth below as follows (the “Protective Order”): 3 1. Applicability of this Protective Order: This Protective Order does not and will 4 not govern pretrial disclosures of exhibits and witnesses under NRCP 26(a)(3), the pretrial order, 5 and trial in this action, but will otherwise be applicable to and govern the handling of documents, 6 depositions, deposition exhibits, interrogatory responses, responses to requests for admissions, 7 responses to requests for production of documents, and all other discovery obtained pursuant to the 8 Nevada Rules of Civil Procedure or other legal process by or from, or produced on behalf of, a party 9 in connection with this action (this information hereinafter referred to as “ Discovery Material”), 10 which, except as otherwise provided herein, shall be used solely for purposes of this action. As used H OLLAND & H ART LLP 9555 H ILLWOOD DRIVE, 2 ND FLOOR LAS VEGAS, NV 89134 11 herein, “Producing Party” or “Disclosing Party” shall refer to the parties in this action that give 12 testimony or produce documents or other information as well as to non -parties who have expressly 13 agreed in writing to be bound by the terms of this Order; “Receiving Party” shall refer to the parties 14 in this action that receive such information, and “Authorized Recipient” shall refer to any person or 15 entity authorized by Sections 10 and 11 of this Protective Order to obtain access to Confidential 16 Information, Highly Confidential Information, or the contents of such Discovery Material. 17 2. Designation of Information: Any Producing Party may designate Discovery 18 Material that is in its possession, custody, or control to be produced to a Receiving Party as 19 “Confidential” or “Highly Confidential” under the terms of this Protective Order if the Producing 20 Party in good faith reasonably believes that such Discovery Material contains non -public, 21 confidential information as defined in Sections 4 and 5 below. 22 3. Exercise of Restraint and Care in Designating Material for Protection: Each 23 Producing Party that designates information or items for protection under this Protective Order must 24 take care to limit any such designation to specific material that qualifies under the appropriate 25 standards. Mass, indiscriminate or routinized designations are prohibited. The Producing Party 26 must designate for protection only those parts of material, documents, items, or oral or written 27 communications that qualify—so that other portions of the material, documents, items, or 28 2 Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document204-1 208 Filed Filed06/22/23 06/21/23 Page Page73ofof25 21 1 communications for which protection is not warranted are not swept unjustifiably within the ambit 2 of this Order. 3 4. Confidential Information: For purposes of this Protective Order, “Confidential 4 Information” means any information that constitutes, reflects, or discloses trade secrets, know-how, 5 proprietary data, marketing information, financial information, and/or commercially sensitive 6 business information or data which the designating party in good faith believes in fact is confidential 7 or the unprotected disclosure of which might result in economic or competitive injury, and which is 8 not publicly known and cannot be ascertained from an inspection of publicly available documents, 9 materials, or devices. Confidential Information shall also include sensitive personal information that 10 is not otherwise publicly available, such as home addresses; Social Security numbers; dates of birth; H OLLAND & H ART LLP 9555 H ILLWOOD DRIVE, 2 ND FLOOR LAS VEGAS, NV 89134 11 employment personnel files; medical information; home telephone records/numbers; employee 12 disciplinary records; wage statements or earnings statements; employee benefits data; tax records; 13 and other similar personal financial information. A party may also designate as “CONFIDENTIAL” 14 compilations of publicly available discovery materials, which would not be known publicly in a 15 compiled form. 16 5. Highly Confidential Information: For purposes of this Protective Order, “Highly 17 Confidential Information” is any Confidential Information, as defined in Section 4, that also includes 18 extremely sensitive, highly confidential, non-public information constituting a trade secret as 19 defined in NRS 600A.030(5) or 18 U.S.C. § 1839(3) and the disclosure of such information would 20 create a substantial risk of competitive or business injury to the Producing Party. 21 6. Designating Confidential Information or Highly Confidential Information. If 22 any party in this action determines in good faith and in accordance with Section 3 above that any 23 documents, things, or responses produced in the course of discovery in this action should be 24 designated as Confidential Information or Highly Confidential Information it shall advise any party 25 who has received such material of this fact, and all copies of such document, things, or responses, 26 or portions thereof deemed to be confidential shall be marked “CONFIDENTIAL” or “HIGHLY 27 CONFIDENTIAL” (whether produced in hard copy or electronic form) at the expense of the 28 designating party and treated as such by all parties. A designating party may inform another party 3 Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document204-1 208 Filed Filed06/22/23 06/21/23 Page Page84ofof25 21 1 that a document is Confidential or Highly Confidential by providing the Bates number of the 2 document in writing. If Confidential Information or Highly Confidential Information is produced 3 via an electronic form on a computer readable medium (e.g., DVD-ROM), other digital storage 4 medium, or via Internet transmission, the Producing Party shall affix in a prominent p lace on the 5 storage medium or container file on which the information is stored, and on any container(s) for such 6 medium, the legend “Includes CONFIDENTIAL INFORMATION” or “Includes HIGHLY 7 CONFIDENTIAL INFORMATION.” Nothing in this section shall extend confidentiality or the 8 protections associated therewith to any information that does not otherwise constitute “Confidential 9 Information” or “Highly Confidential Information” as defined in Sections 4 and 5 herein. 10 7. Redaction Allowed: Any Producing Party may redact from the Discovery Material H OLLAND & H ART LLP 9555 H ILLWOOD DRIVE, 2 ND FLOOR LAS VEGAS, NV 89134 11 it produces matter that the Producing Party claims is subject to the attorney -client privilege, the work 12 product doctrine, a legal prohibition against disclosure, or any other privilege from disclosure. Any 13 Producing Party also may redact information that is both personal and non -responsive, such as a 14 social security number. A Producing Party may not redact information in an otherwise responsive 15 document solely because the Producing Party believes that the information is non-responsive. Nor 16 shall a Producing Party withhold non-privileged, responsive information solely on the grounds that 17 such information is contained in a document that includes privileged information. The Producing 18 Party shall mark each Discovery Material where matter has been redacted with a legend stating 19 “REDACTED,” and include an annotation indicating the specific reason for the redaction ( e.g., 20 “REDACTED—Work Product”). All documents that have been redacted shall be listed in a 21 redaction log produced in conformity with Nevada law and the Nevada Rules of Civil Procedure. 22 Where a document consists of more than one page, the page on which information has been redacted 23 shall so be marked. The Producing Party shall preserve an unredacted version of eac h such 24 document. 25 8. Use of Confidential Information or Highly Confidential Information. Except 26 as provided herein, Confidential Information and Highly Confidential Information designated or 27 marked as provided herein shall be used solely for the purposes of this action, shall not be disclosed 28 to anyone other than those persons identified herein in Sections 10 and 11, and shall be handled in 4 Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document204-1 208 Filed Filed06/22/23 06/21/23 Page Page95ofof25 21 1 such manner until such designation is removed by the designating party or by order of the Court. 2 Nothing in this Protective Order shall preclude a party or other person from using his, her, or its own 3 Confidential Information or Highly Confidential Information or from giving others his, her, or its 4 Confidential Information or Highly Confidential Information. 5 Once the Court enters this Protective Order, a party shall have thirty (30) days to designate 6 as Confidential or Highly Confidential any documents previously produced in this action, which it 7 can do by stamping “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” on the document, or 8 informing the other parties of the Bates-numbers of the documents so designated. 9 9. 10 Depositions. Use of Confidential Information and Highly Confidential Information in Counsel for any party shall have the right to disclose Confidential or Highly H OLLAND & H ART LLP 9555 H ILLWOOD DRIVE, 2 ND FLOOR LAS VEGAS, NV 89134 11 Confidential Information at depositions, provided that such disclosure is consistent with this 12 Protective Order, including Sections 10 and 11. Any counsel of record may request that all persons 13 not entitled under Sections 10 or 11 of this Protective Order to ha ve access to Confidential 14 Information or Highly Confidential Information leave the deposition room during the confidential 15 portion of the deposition. Failure of such other persons to comply with a request to leave the 16 deposition shall constitute substantial justification for counsel to advise the witness that the witness 17 need not answer the question where the answer would disclose Confidential Information or Highly 18 Confidential Information. However, nothing in this Order shall preclude a party or its atto rneys 19 from: (1) showing a document designated as Confidential or Highly Confidential to an individual 20 who prepared part or all of the document, who has previously reviewed the document, or who is 21 shown by the document to have received it, or (2) examining during a deposition any person 22 currently employed by a party or retained as an expert by a party concerning any Discovery Materials 23 designated by that party as Confidential or Highly Confidential, which use shall not otherwise affect 24 the status and treatment of such Confidential or Highly Confidential Information. Additionally, at 25 any deposition session, counsel to any party (or non -party subject to this Protective Order) may 26 designate portions of a deposition transcript and/or video of any deposition (or any other testimony) 27 as containing Confidential or Highly Confidential Information in accordance with this Order by a 28 statement on the record during the deposition or by notifying all other parties in writing within 5 Case Case 2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document 204-1 208 Filed Filed06/22/23 06/21/23 Page Page106 of of 25 21 1 fourteen (14) calendar days of receiving the official transcript or video that it contains Confidential 2 and/or Highly Confidential Information. Counsel must follow up in writing within thirty (30) 3 calendar days of receiving the official transcript or video, identifying the specific pages, lines , and/or 4 counter numbers containing the Confidential or Highly Confidential Information. If no 5 confidentiality designations are made within the thirty calendar (30) day period, the entire transcript 6 shall be considered non-confidential. If a deposition is designated as Confidential or Highly 7 Confidential by a statement on the record during the deposition, then during the thirty (30) day 8 period, the entire transcript and video shall be treated as Confidential Information (or Highly 9 Confidential Information if so designated). If a deposition is not designated as Confidential or 10 Highly Confidential by a statement on the record during the deposition, the entire transcript and H OLLAND & H ART LLP 9555 H ILLWOOD DRIVE, 2 ND FLOOR LAS VEGAS, NV 89134 11 video shall be treated (i) as Highly Confidential Information through the end of the 14 (fourteen) 12 day period for designation by written notice and (ii) thereafter during the 30 (thirty) day period as 13 Confidential Information or Highly Confidential Information if so designated. All originals and 14 copies of deposition transcripts that contain Confidential Information or Highly Confidential 15 Information shall be prominently marked “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” on 16 the cover thereof and, if and when filed with the Court, the portions of such transcript so designated 17 shall be requested to be filed under seal in accordance with SRCR 3. Counsel must designate 18 portions of a deposition transcript as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” within 19 thirty calendar (30) days of receiving the official transcript. Any DVD or other digital stora ge 20 medium containing Confidential or Highly Confidential deposition testimony shall be labeled in 21 accordance with the provisions of Section 6. The provisions set forth in Section 17 shall govern 22 resolution of disputes over confidentiality designations regarding deposition transcripts. 23 10. Persons Authorized to Receive Confidential Information. Confidential 24 Information produced pursuant to this Protective Order may be disclosed or made available only to 25 the Court, court personnel, and to the persons below: 26 27 a) A party, or officers, directors, and employees of a party deemed necessary by counsel to aid in the prosecution, defense, or settlement of this action; 28 6 Case Case 2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document 204-1 208 Filed Filed06/22/23 06/21/23 Page Page117 of of 25 21 1 b) Counsel for a party and its affiliates (including in-house attorneys, outside 2 attorneys, and paralegal, clerical, litigation support staff, and secretarial staff 3 employed by such counsel); 4 c) An entity retained by a party to provide litigation support services (photocopying, 5 videotaping, translating, preparing exhibits or demonstrations, organizing, storing, 6 retrieving data in any form or medium, etc.) and its employees; 7 d) Outside experts or consultants (together with their support staff) retained by a 8 party to assist in the prosecution, defense, or settlement of this action, provided 9 that such an expert or consultant is not a current employee of a direct competitor H OLLAND & H ART LLP 9555 H ILLWOOD DRIVE, 2 ND FLOOR LAS VEGAS, NV 89134 10 of a party named in this action; 11 e) Court reporter(s) or videographers(s) employed in this action; 12 f) A witness at any deposition or other proceeding in this action (1) to whom 13 Confidential may be provided as set forth in Section 8 or (2) to whom the 14 Producing Party agrees may be shown certain Discovery Materials designated as 15 Confidential Information; 16 g) Any ESI vendor, translator(s), or interpreter(s) employed in this action; 17 h) Any other person as to whom the parties in writing agree or that the Court in these 18 proceedings designates; and 19 i) Jury consultants or trial consultants retained by or on behalf of a party to assist 20 outside counsel for any party in connection with this litigation, together with 21 technicians, assistants, or mock jurors who (i) are supervised by such consultants; 22 (ii) are not affiliated with any party to this case or their direct competitor; (iii) 23 agree in writing to be bound by confidentiality; and (iv) are not themselves given 24 custody of any Confidential Information, nor permitted to remove any 25 presentations, questionnaires or notes taken during the exercise from any room in 26 which the research is conducted. 27 Any person to whom Confidential Information is disclosed pursuant to subparts (a), (b), 28 (c), (d), (e), (f), (g), (h), or (i) above shall be advised that the Confidential Information is being 7 Case Case 2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document 204-1 208 Filed Filed06/22/23 06/21/23 Page Page128 of of 25 21 1 disclosed pursuant to an order of the Court, that the information may not be disclosed by such 2 person to any person not permitted to have access to the Confidential Information pursuant to this 3 Protective Order, and that any violation of this Protective Order may result in the imposition of 4 such sanctions as the Court deems proper. Any person to whom Confidential Information is 5 disclosed pursuant to subpart (c), (d), (g), (h), or (i) of this Section shall also be required to execute 6 a copy of the form Exhibit A. The persons shall agree in writing to be bound by the terms of this 7 Protective Order by executing a copy of Exhibit A (which shall be maintained b y the counsel of 8 record for the party seeking to reveal the Confidential Information) in advance of being shown the 9 Confidential Information. No party (or its counsel) shall discourage any persons from signing a 10 copy of Exhibit A. If a person refuses to execute a copy of Exhibit A, the party seeking to reveal H OLLAND & H ART LLP 9555 H ILLWOOD DRIVE, 2 ND FLOOR LAS VEGAS, NV 89134 11 the Confidential Information may seek an order from the Court directing that the person be bound 12 by this Protective Order. In the event of the filing of such a motion, Confidential Information may 13 not be disclosed to such person until the Court resolves the issue. Proof of each written agreement 14 provided for under this Section shall be maintained by each of the parties while this action is 15 pending and disclosed to the other parties if ordered to do so by the Court. 16 11. Persons Authorized to Receive Highly Confidential Information. “HIGHLY 17 CONFIDENTIAL” documents and information may be used only in connection with this case and 18 may be disclosed only to the Court, court personnel, and the persons listed in sub-sections (b) to (i) 19 of Section 10 above, but shall not be disclosed to a party, or an employee of a party (other than in20 house counsel for a party), unless otherwise agreed or ordered. Any person to whom Highly 21 Confidential Information is disclosed pursuant to sub-sections (c), (d), (g), (h), or (i) of Section 10 22 above shall also be required to execute a copy of the form Exhibit A, and shall be subject to the 23 requirements in the preceding paragraph. 24 12. Filing of Confidential Information or Highly Confidential Information with 25 the Court. Any party seeking to file or disclose materials designated as Confidential Information 26 or Highly Confidential Information with the Court in this action must, concurrently with or prior to 27 any such filing, seek leave to file such Confidential Information or Highly Confidential Information 28 under seal in accordance with SRCR 3. 8 Case Case 2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document 204-1 208 Filed Filed06/22/23 06/21/23 Page Page139 of of 25 21 1 13. Notice to Non-Parties. Any party issuing a subpoena to a non-party shall enclose 2 a copy of this Protective Order with a request that, within ten (10) calendar days, the non-party either 3 request the protection of this Protective Order or notify the issuing party that the non -party does not 4 need the protection of this Protective Order or wishes to seek different protection. Any non -party 5 invoking the Protective Order shall comply with, and be subject to, all other applicable sections of 6 the Protective Order. 7 14. Knowledge of Unauthorized Use or Possession. If a party receiving Confidential 8 Information or Highly Confidential Information learns of any unauthorized possession, knowledge, 9 use or disclosure of any Confidential Information or Highly Confidential Information, the Receiving 10 Party shall immediately notify in writing the party that produced the Confidential Information or H OLLAND & H ART LLP 9555 H ILLWOOD DRIVE, 2 ND FLOOR LAS VEGAS, NV 89134 11 Highly Confidential Information. The Receiving Party shall promptly furnish the Producing Party 12 the full details of such possession, knowledge, use or disclosure, shall make all reasonable efforts to 13 retrieve the improperly disclosed information and to prevent further disclosure by each unauthorized 14 person who received such information. With respect to such unauthorized possession, knowledge, 15 use or disclosure the Receiving Party shall assist the Producing Party in preventing its recurrence. 16 15. Copies, Summaries or Abstracts. Any copies, summaries, abstracts or exact 17 duplications of Confidential Information or Highly Confidential Information shall be marked 18 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” and shall be considered Confidential 19 Information or Highly Confidential Information subject to the terms and conditions of this Protective 20 Order. Attorney-client communications and attorney work product regarding Confidential 21 Information or Highly Confidential Information shall not be subject to this Section, regardless of 22 whether they summarize, abstract, paraphrase, or otherwise reflect Confidential Information or 23 Highly Confidential Information. This Order shall not bar or otherwise restrict any attorney of record 24 from rendering advice to his or her client with respect to this litigation, and referring to or relying 25 generally upon his or her examination of Discovery Material designated as Confidential or Highly 26 Confidential, provided, however, that in communicating with his or her client, the attorney shall not 27 disclose the content or source of such Discovery Material contrary to the terms of this Order. 28 9 Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document204-1 208 Filed Filed06/22/23 06/21/23 Page Page14 10ofof25 21 1 16. Information Not Confidential. The restrictions set forth in this Protective Order 2 shall not be construed to apply to any information or materials that: 3 a) Were lawfully in the Receiving Party’s possession prior to such information 4 being designated as Confidential Information or Highly Confidential 5 Information in this action, and that the Receiving Party is not otherwise obligated 6 to treat as confidential; 7 b) Were obtained without any benefit or use of Confidential Information or Highly 8 Confidential Information from a third party having the right to disclose such 9 information to the Receiving Party without restriction or obligation of H OLLAND & H ART LLP 9555 H ILLWOOD DRIVE, 2 ND FLOOR LAS VEGAS, NV 89134 10 confidentiality; 11 c) Were independently developed after the time of disclosure by personnel who did 12 not have access to the Producing Party’s Confidential Information or Highly 13 Confidential Information; 14 d) Have been or become part of the public domain by publication or otherwise and 15 not due to any unauthorized act or omission on the part of a Receiving Party; or 16 17 e) Under law, have been declared to be in the public domain. 17. Challenges to Designations. Any party may object to the designation of 18 Confidential Information or Highly Confidential Information on the ground that such information 19 does not constitute Confidential Information or Highly Confidential Information by serving written 20 notice upon counsel for the Producing Party, specifying the item(s) by Bates number. The parties 21 shall attempt to resolve each challenge in good faith through a meet and confer (as set forth in NRCP 22 26(c)(1) and EDCR 2.34(d)) to be initiated by the Producing Party within fourteen (14) days of the 23 date of service of the notice. If the parties cannot resolve a challenge without court intervention, the 24 Producing Party shall file and serve a motion to retain confidentiality within twenty -one (21) days 25 of the initial notice of challenge or within fourteen (14) days of the parties agreeing that the meet 26 and confer process will not resolve their dispute, whichever is earlier. Failure by the Producing 27 Party to make such a motion (including the declaration required under NRCP 26(c)(1) and EDCR 28 2.34(d) within twenty-one (21) days (or fourteen (14) days, if applicable) shall automatically waive 10 Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document204-1 208 Filed Filed06/22/23 06/21/23 Page Page15 11ofof25 21 1 the confidentiality designation for each challenged designation. The burden of persuasion in any 2 such challenge proceeding shall be on the Producing Party. Unless the Producing Party has waived 3 the confidentiality designation by failing to file a motion to retain confidentiality as described above, 4 all parties shall continue to afford the material in question the level of protection to which it is 5 entitled under the Producing Party’s designation until the Court rules on the motion. 6 18. Use in Court. If any Confidential Information or Highly Confidential Information 7 is used in any pretrial Court proceeding in this action, it shall not necessarily lose its confidential 8 status through such use, and the party using such information shall take all reasonable steps to 9 maintain its confidentiality during such use. 10 19. No Waiver. This Protective Order is entered solely for the purpose of facilitating H OLLAND & H ART LLP 9555 H ILLWOOD DRIVE, 2 ND FLOOR LAS VEGAS, NV 89134 11 the exchange of documents and information among the parties to this action without involving the 12 Court unnecessarily in the process. Nothing in this Protective Order nor the prod uction of any 13 information or document under the terms of this Protective Order, nor any proceedings pursuant to 14 this Protective Order shall be deemed to be a waiver of any rights or objections to challenge the 15 authenticity or admissibility of any document, testimony or other evidence at trial. Additionally, 16 this Protective Order will not prejudice the right of any party or nonparty to oppose production of 17 any information on the ground of attorney-client privilege; work product doctrine or any other 18 privilege or protection provided under the law. Entry of this Protective Order does not preclude any 19 party from seeking or opposing additional protection for particular information. 20 20. Reservation of Rights. The Parties each reserve (1) the right to seek or oppose 21 additional or different protection for particular information, documents, materials, items or things; 22 and (2) the right to object to the production, disclosure and/or use of any information, documents, 23 materials, items and/or things that a party designates or marks as containing Confidential 24 Information or Highly Confidential Information on any other ground(s) it may deem appropriate, 25 including, without limitation, on the ground of attorney-client privilege, work product, and/or any 26 other privilege or protection provided under applicable law. This Protective Order shall neither 27 enlarge nor affect the proper scope of discovery in this action. In addition, this Protective Order 28 shall not limit or circumscribe in any manner any rights the Parties (or their respective counsel) may 11 Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document204-1 208 Filed Filed06/22/23 06/21/23 Page Page16 12ofof25 21 1 have under common law or pursuant to any state, federal, or foreign statute or regulation, and/or 2 ethical rule. 3 21. Inadvertent Failure to Designate. The inadvertent failure to designate 4 information produced in discovery as Confidential or Highly Confidential shall not be deemed, by 5 itself, to be a waiver of the right to so designate such discovery materials as Confidential Information 6 or Highly Confidential Information. Within a reasonable time of learning of any such inadvertent 7 failure, the Producing Party shall notify all receiving parties of such inadvertent failure and take such 8 other steps as necessary to correct such failure after becoming aware of it. Disclosure of such 9 discovery materials to any other person prior to later designation of the discovery materials in 10 accordance with this Section shall not violate the terms of this Protective Order. However, H OLLAND & H ART LLP 9555 H ILLWOOD DRIVE, 2 ND FLOOR LAS VEGAS, NV 89134 11 immediately upon being notified of an inadvertent failure to designate, all parties shall treat such 12 information as though properly designated and take any actions necessary to prevent any 13 unauthorized disclosure subject to the provisions of Section 1 4, including seeking retrieval or 14 destruction of any copies distributed to unauthorized individuals, and destroying copies of 15 documents that have been replaced with the proper designation. 16 22. No Waiver of Privilege: Inadvertent disclosure (including production) of 17 information that a party or non-party later claims should not have been disclosed because of a 18 privilege, including, but not limited to, the attorney-client privilege or work product doctrine 19 (“Privileged Information”), shall not constitute a waiver of, or estoppel as to, any claim of attorney20 client privilege, attorney work product, or other ground for withholding production as to which the 21 Disclosing or Producing Party would be entitled in the action. Promptly upon learning of the 22 inadvertent disclosure, however, the Producing Party must notify the Receiving Party of the 23 inadvertent production and request return, sequestration, or destruction of documents. 24 23. Effect of Disclosure of Privileged Information: The Receiving Party hereby 25 agrees to return, sequester, or destroy any Privileged Information disclosed or produced by 26 Disclosing or Producing Party upon request; but doing so shall not preclude the Receiving Party 27 from seeking to compel production of those materials, nor constitute an admission that the materials 28 were, in fact, privileged, and the Producing Party must preserve any such documents. If the 12 Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document204-1 208 Filed Filed06/22/23 06/21/23 Page Page17 13ofof25 21 1 Receiving Party reasonably believes that Privileged Information has been inadvertently disclosed or 2 produced to it, it shall promptly notify the Disclosing or Producing Party and sequester such 3 information until instructions as to disposition are received. 4 24. Inadvertent Production of Non-Discoverable Documents. If a Producing Party 5 inadvertently produces a document that contains no discoverable information, the Producing Party 6 may request in writing that the Receiving Party return the document, and the Receiving Party will 7 return the document. A Producing Party may not request the return of a document pursuant to this 8 paragraph if the document contains any discoverable information. If a Producing Party inadvertently 9 fails to redact personal information (for example, a social security number), the Producing Party may 10 provide the Receiving Party a substitute version of the document that redacts the personal H OLLAND & H ART LLP 9555 H ILLWOOD DRIVE, 2 ND FLOOR LAS VEGAS, NV 89134 11 information, and the Receiving Party shall destroy or return the original, unredacted document to 12 the Producing Party. 13 25. Return of Information. Within thirty (30) calendar days after the final disposition 14 of this action, all Confidential or Highly Confidential Discovery Material produced by an opposing 15 party or non-party (including, without limitation, any copies, extracts or summaries thereof) as part 16 of discovery in this action shall be destroyed by the parties to whom the Confidential or Highly 17 Confidential Discovery Material was produced, and each counsel shall, by declaration delivered to 18 all counsel for the Producing Party, affirm that all such Confidential or Highly Confidential 19 Discovery Material (including, without limitation, any copies, extracts or summaries thereof) has 20 been destroyed; provided, however, that each counsel shall be entitled to retain pleadings, motions 21 and memoranda in support thereof, declarations or affidavits, deposition transcripts and videotapes, 22 or documents reflecting attorney work product or consultant or expert work product, even if such 23 material contains or refers to Confidential or Highly Confidential Discovery Material, but only to 24 the extent necessary to preserve a litigation file with respect to this action. 25 26. Attorney’s Fees. Nothing in this Protective Order is intended to either expand or 26 limit a prevailing Party’s right under the Nevada Rules of Civil Procedure or other applicable state 27 or federal law to pursue costs and attorney’s fees incurred related to confidentiality designations or 28 the abuse of the process described herein. 13 Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document204-1 208 Filed Filed06/22/23 06/21/23 Page Page18 14ofof25 21 1 27. Injunctive Relief Available. Each party acknowledges that monetary remedies 2 may be inadequate to protect each party in the case of unauthorized disclosure or use of Confidential 3 Information or Highly Confidential Information that the Receiving Party only received through 4 discovery in this action and that injunctive relief may be appropriate to protect each party’s rights in 5 the event there is any such unauthorized disclosure or use of Confidential Information or Highly 6 Confidential Information. 7 28. Other Actions and Proceedings. If a Receiving Party (a) is subpoenaed in another 8 action or proceeding, (b) is served with a demand in another action or proceeding in which it is a 9 party, or (c) is served with any legal process by one not a party to this Protective Order, seeking 10 materials which were produced or designated as Confidential or Highly Confidential pursuant to this H OLLAND & H ART LLP 9555 H ILLWOOD DRIVE, 2 ND FLOOR LAS VEGAS, NV 89134 11 Protective Order, the Receiving Party shall give prompt actual written notice by email or mail to 12 counsel of record for such Producing Party within five (5) business days of receipt of such subpoena, 13 demand or legal process or such shorter notice as may be required to provide other parties with the 14 opportunity to object to the immediate production of the requested discovery materials to the extent 15 permitted by law. The burden of opposing enforcement of the subpoena shall fall upon the party or 16 non-party who produced or designated the Discovery Material as Confidential Information or Highly 17 Confidential Information. The party receiving the subpoena shall not produce any documents in 18 response to the subpoena until the party whose Discovery Material was produced in this case has 19 reasonable time to seek court protection from such production in response to the subpoena in the 20 action or proceeding. 21 29. Execution in Counterparts. This Protective Order may be executed in any 22 number of duplicate originals, each of which is deemed an original, and in any number of 23 counterparts, each of which is deemed an original, and all of which together constitute a fully 24 executed agreement (even though all signatures may not appear on the same document). A signed 25 copy of this Protective Order delivered by facsimile, portable document format (.pdf), or other means 26 of electronic transmission is deemed to have the same legal force and effect as delivery of an original 27 ink signed copy of this Protective Order. 28 14 Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document204-1 208 Filed Filed06/22/23 06/21/23 Page Page19 15ofof25 21 1 30. Order Survives Termination. This Protective Order shall survive the termination 2 of this action, and the Court shall retain jurisdiction to resolve any dispute concerning the use of 3 information disclosed hereunder. 4 5 HOLLAND & HART LLP SLIGHTING LAW 6 /s/ Lars K. Evensen Lars K. Evensen, Esq. Jenapher Lin, Esq. 9555 Hillwood Drive, 2nd Floor Las Vegas, NV 89134 /s/ Bradley S. Slighting Bradley S. Slighting (NBN 10225) 1707 Village Center Cir, Ste 100 Las Vegas, NV 89134 Tel: (702) 840-3749 brad@slightinglaw.com 7 8 9 11 KERR SIMPSON ATTORNEYS AT LAW P. Sterling Kerr, Esq. George E. Robinson, Esq. 2900 W. Horizon Ridge Parkway, Suite 200 Henderson, NV 89052 12 Attorneys for Plaintiff 10 H OLLAND & H ART LLP 9555 H ILLWOOD DRIVE, 2 ND FLOOR LAS VEGAS, NV 89134 DATED this 6th day of October 2022. Scott Wellman (pro hac vice forthcoming) Chris Wellman (pro hac vice forthcoming) WELLMAN & WARREN LLP 24411 Ridge Route, Suite 200 Laguna Hills, CA 92653 Tel: (949) 580-3737 swellman@w-wlaw.com cwellman@w-wlaw.com 13 14 Attorneys for Defendants DAVID IMONITIE; SPELA SLUGA; DEVON ROESER; NVISIONU, INC. 15 16 ORDER 17 IT IS SO ORDERED. 18 DATED this ___ day of ______________2022. 19 20 21 DISTRICT COURT JUDGE 22 23 24 25 26 27 28 15 Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document204-1 208 Filed Filed06/22/23 06/21/23 Page Page20 16ofof25 21 1 EXHIBIT A 2 CONFIDENTIALITY AGREEMENT 3 I, ______________________________ do hereby acknowledge and agree, under penalty of 4 perjury under the law of the State of Nevada, as follows: 5 1. I have read the Protective Order regarding Confidentiality (“the Protective Order”) 6 entered in International Markets Live Inc. v. David Imonitie et al., case no. A-22-854783-B, in the 7 Eighth Judicial District Court of the State of Nevada, on _______________ ___, 202_, and I fully 8 understand its contents. 9 2. I hereby agree and consent to be bound by the terms of the Protective Order and to 10 comply with it in all respects, and to that end, I hereby knowingly and voluntarily submit and subject H OLLAND & H ART LLP 9555 H ILLWOOD DRIVE, 2 ND FLOOR LAS VEGAS, NV 89134 11 myself to the personal jurisdiction of the Eighth Judicial District Court of the State of Nevada so that the 12 said court shall have the power and authority to enforce the Protective Order and to impose appropriate 13 sanctions upon me for knowingly violating the Protective Order, including punishment for contempt of 14 court for a knowing violation of the Protective Order. 15 3. I understand that by signing this instrument, I will be eligible to receive 16 “Confidential Information” or “Highly Confidential Information” under the terms and conditions 17 of the Protective Order. I further understand and agree that I must treat any “Confidential 18 Information” or “Highly Confidential Information” in accordance with the terms and conditions of 19 the Protective Order, and that, if I should knowingly make a disclosure of any such information in 20 a manner unauthorized by the Protective Order, I will have violated a court order, will be in 21 contempt of court, and will be subject to punishment by the court for such conduct. 22 DATED: ______________ ___, 202__. __________________________________ (Signature) 23 24 __________________________________ (Printed Name) 25 __________________________________ 26 __________________________________ (Address) 27 28 16 Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document204-1 208 Filed Filed06/22/23 06/21/23 Page Page21 17ofof25 21 Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document204-1 208 Filed Filed06/22/23 06/21/23 Page Page22 18ofof25 21 Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document204-1 208 Filed Filed06/22/23 06/21/23 Page Page23 19ofof25 21 From: Scott Wellman <swellman@w-wlaw.com> Sent: Tuesday, October 4, 2022 7:24 PM To: Chris Wellman <cwellman@w-wlaw.com>; Cynthia English <cenglish@w-wlaw.com> Subject: Fwd: IML v Imonitie et al (A-22-854783-B) - SPO & ESI Protocols Get Outlook for iOS From: Jenapher Lin <JLin@hollandhart.com> Sent: Tuesday, October 4, 2022 6:16:49 PM To: Scott Wellman <swellman@w-wlaw.com>; brad@slightinglaw.com <brad@slightinglaw.com> Cc: Lars Evensen <LKEvensen@hollandhart.com>; George Robinson <george@kerrsimpsonlaw.com>; Sterling Kerr <sterling@kerrsimpsonlaw.com> Subject: IML v Imonitie et al (A-22-854783-B) - SPO & ESI Protocols Counsel, Attached, please find for your review/approval drafts of our proposed (1) Stipulated Protective Order regarding Confidentiality and (2) SAO regarding Protocol Governing Production of ESI in the above-referenced matter. Please provide any proposed edits/comments you may have and/or, if otherwise acceptable, please respond with authorization to affix your e-signature on each of the attached for finalization and submission to the Court. Thank you. Sincerely, Jenapher Jenapher Lin Associate, Holland & Hart LLP 9555 Hillwood Drive, Second Floor, Las Vegas, NV 89134 T 702.222.2571 F 702.823.0229 CONFIDENTIALITY NOTICE: This message is confidential and may be privileged. If you believe that this email has been sent to you in error, please reply to the sender that you received the message in error; then please delete this e-mail. CAUTION: This email originated from outside of the company. Do not click links or open attachments unless you recognize the sender and know the content is safe. NEVER enter your email address and password if requested by any website. 3 Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document204-1 208 Filed Filed06/22/23 06/21/23 Page Page24 20ofof25 21 1 CSERV 2 DISTRICT COURT CLARK COUNTY, NEVADA 3 4 5 6 7 8 9 International Markets Inc, Plaintiff(s) CASE NO: A-22-854783-B DEPT. NO. Department 16 vs. David Imonitie, Defendant(s) 10 AUTOMATED CERTIFICATE OF SERVICE 11 12 13 14 15 This automated certificate of service was generated by the Eighth Judicial District Court. The foregoing Stipulated Protective Order was served via the court’s electronic eFile system to all recipients registered for e-Service on the above entitled case as listed below: Service Date: 10/7/2022 Valerie Larsen vllarsen@hollandhart.com Lisa Peters lisa@kerrsimpsonlaw.com Jennifer Hogan jennifer@kerrsimpsonlaw.com 19 George Robinson george@kerrsimpsonlaw.com 20 Sterling Kerr sterling@kerrsimpsonlaw.com 21 Lars Evensen lkevensen@hollandhart.com Breana Talley breana@kerrsimpsonlaw.com Jenapher Lin jlin@hollandhart.com Brenda Schroeder blschroeder@hollandhart.com 26 Bradley Slighting brad@slightinglaw.com 27 Cynthia English cenglish@w-wlaw.com 16 17 18 22 23 24 25 28 Case Case2:22-cv-01863-GMN-BNW 2:22-cv-01863-GMN-BNW Document Document204-1 208 Filed Filed06/22/23 06/21/23 Page Page25 21ofof25 21 1 Scott Wellman swellman@w-wlaw.com Jon Field jfield@thompsonburton.com 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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