Valverde v. Xclusive Staffing, Inc. et alMOTION for Leave to RestrictD. Colo.August 5, 2016 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Case No. 16-cv-00671-MSK-MJW ISABEL VALVERDE; MARIA SONIA MICOL SIMON; and those similarly situated Plaintiffs, v. XCLUSIVE STAFFING, INC.; XCLUSIVE MANAGEMENT, LLC D.B.A. XCLUSIVE STAFFING; XCLUSIVE STAFFING OF COLORADO, LLC; DIANE ASTLEY; OMNI INTERLOCKEN COMPANY, L.L.C.; OMNI HOTELS MANAGEMENT CORPORATION; JMIR DTC OPERATOR LLC; MARRIOTT INTERNATIONAL, INC.; and HCA-HEALTHONE LLC D.B.A. SKY RIDGE MEDICAL CENTER Defendants. MOTION TO RESTRICT DOCUMENT (DKT. NO. 52-5) CERTIFICATE OF CONFERAL PURSUANT TO D.C.COLO.LCIV.R. 7.1(A) Plaintiffs’ counsel conferred with Defendants’ counsel prior to filing this Motion. Defendants do not oppose this Motion. MOTION TO RESTRICT Plaintiffs filed Exhibit 5 to their First Amended Complaint (Dkt. No. 52-5) as a restricted document. Defendants disclosed that document to Plaintiffs and designated it as “confidential.” Plaintiffs have not opposed that designation. Pursuant to the Court’s Protective Order, Dkt. No. Case 1:16-cv-00671-RM-MJW Document 64 Filed 08/05/16 USDC Colorado Page 1 of 3 2 51 at ¶ 9, because Plaintiffs seek to file with the Court a document designated “confidential,” it is Plaintiffs’ responsibility to move to restrict that document under D.C.COLO.LCiv.R. 7.2. Notwithstanding that Local Rule 7.2 states that “stipulations between the parties or stipulated protective orders with regard to discovery, alone, are insufficient to justify restriction,” Plaintiffs understand the Protective Order as requiring them to file this Motion. Besides its designation as “confidential,” however, Plaintiffs do not have any other basis for thinking Exhibit 5 to the First Amended Complaint (Dkt. No. 52-5) should be restricted. Respectfully Submitted, s/David H. Seligman___ David H. Seligman Towards Justice 1535 High St., Suite 300 Denver, CO 80218 Tel.: 720-248-8426 Fax: 303-957-2289 Email: david@towardsjustice.org Attorney for Plaintiffs Case 1:16-cv-00671-RM-MJW Document 64 Filed 08/05/16 USDC Colorado Page 2 of 3 3 Certificate of Service I hereby certify that on 8/5/2016, I served a true and correct copy of the forgoing on all parties that have appeared pursuant to F.R.C.P. 5. s/David H. Seligman__ David H. Seligman Case 1:16-cv-00671-RM-MJW Document 64 Filed 08/05/16 USDC Colorado Page 3 of 3
