COURT , A § MINOR, et al § § PLAINTIFFS, § § v. § 370TH JUDICIAL DISTRICT § NCDR, LLC d/b/a KOOL SMILES, et al § § DEFENDANTS. § HIDALGO COUNTY, TEXAS
PLAINTIFFS' MOTION TO AMEND CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER OR, ALTERNATIVELY, MOTION FOR SANCTIONS OR, ALTERNATIVELY, FOR DETERMINATION OF CONFIDENTIALITY
TO THE HONORABLE NOE GONZALEZ, JUDGE PRESIDING:
COME NOW Plaintiffs PAULA ANTU AS NEXT FRIEND OF
, A MINOR; SCARLETT AYALA AS NEXT FRIEND OF ,A
IVIINOR; GUADALUPE CEPEDA AS NEXT FRIEND OF , A l'vUNOR;
ANA LAURA CORNEJO AS NEXT FRIEND OF , A MINOR;
MARIO CUELLAR AND PRISCILLA TRUJILLO AS NEXT FRIENDS OF
, A MINOR; MARIA GAYTAN AS NEXT FRIEND OF
, A MINOR; ELIZABETH GONZALEZ AND MARCO REYES AS NEXT FRIENDS OF
, A MINOR; FRANCISCA GUZMAN AS NEXT FRIEND OF
, A MINOR; ISMAEL MALDONADO AND ISABEL MALDONADO AS NEXT
FRIENDS OF , A MINOR; FREIS! OLIV AR AS NEXT FRIEND
OF A MINOR; :tvfARY ROSALES AS NEXT FRIEND OF
A MINOR; AND REYNOL SALINAS AS NEXT FRIEND OF
A MINOR, (herejnafter collectively referred to as "Plaintiffs,,) and file this, Plaintiffs'
Motion To Amend Confidentiality Agreement And Protective Order Or, Alternatively, Motion Nov. 17. 2014 4:46PM No. 38 04 P. 4/ 42
For Sanctions Or, Alternatively, For Determination Of Confidentiality. In supp01t of same,
Plaintiffs would show unto this Honorable Couti as follov.rs:
I. PROCEDURAL HISTORY
On June 11, 2013, the parties agfeed to, and the Court entered, a Stip\.llated
Confidentiality Agreement and Protective Order (the "Protective Order'} A copy of the
Protective Order is attached hereto as Exhibit "A". Pursuant to said order, Defendants Dentistry
of Brownsville, P.C. d/b/a Kool Smiles, NCDR, LLC d/b/a Kool Smiles and Kool Smiles, P.C.
dlb/u Kool Smiles (hereinafter together referred to as "Defendants") were permitted to designate
documents produced as either "Confidential" and/or "Produced Pursuant to Protective Order" if
said documents contain tr