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Basharel v. Sam's West Inc.

United States District Court, D. Nevada

March 27, 2017

TINA LOUISE BASHAREL, an individual, Plaintiff,
v.
SAM'S WEST, INC., d/b/a SAM'S CLUB #6257, a foreign corporation; WAL-MART STORES, INC., a foreign corporation; KRG LAS VEGAS CENTENNIAL CENTER, LLC a foreign limited-liability company; JOHN ALCALA; MIKE OSUNA; DOE STORE MANAGERS I through X; DOE STORE EMPLOYEES I through X; DOE OWNERS I through X; DOE PROPERTY MANAGERS I through X; DOE MAINTENANCE EMPLOYEES I through X; DOE JANITORIAL EMPLOYEES I through X; ROE PROPERTY MANAGERS XI through XX; ROE MAINTENANCE COMPANIES XI through XX; ROE OWNERS XI through XX; ROE EMPLOYERS XI through XX; DOES XXI through XXV; and ROE CORPORATIONS XXV through XXX. inclusive, jointly and severally, Defendants.

          MORRIS ANDERSON Isl Kimball Jones KIMBALL JONES, ESQ. Nevada Bar No. 12982 Attorneys for Plaint[{(Tina Louis Basharel

          PHILLIPS, SPALLAS & ANGSTADT, LLC Isl Daniel H Prepas DANIEL H. PREPAS, ESQ. Nevada Bar No. 13937 Attorneysfor Defendant Sam 's West, Inc.

          STIPULATED PROTECTIVE ORDER BETWEEN PLAINTIFF TINA LOUISE BASHAREL AND DEFENDANT SAM'S WEST, INC.

         STIPULATED PROTECTIVE ORDER

         The parties to this action. Defendant Sam's West, Inc. (hereinafter "Defendant"), and Plaintiff Tine Louise Basharel (hereinafter "Plaintiff), by their respective counsel, hereby stipulate and request that the Court enter a stipulated protective order pursuant as follows:

         1. The Protective Order shall be entered pursuant to the Federal Rules of Civil Procedure.

         2. The Protective Order shall govern all materials deemed to be '"Confidential Information." Such Confidential Information shall include the following:

(a) Any and all documents referring or related to confidential and proprietary human resources or business information; financial records of the parties; compensation of Defendant's current or former personnel; policies, procedures and/or training materials of Defendant and/or Defendant's organizational structure;
(b) Any documents from the personnel, medical or workers' compensation file of any current or former employee or contractor;
(c) Any documents relating to the medical and/or health information of any of Defendant's current or former employees or contractors;
(d) Any portions of depositions (audio or video) where Confidential Information is disclosed or used as exhibits.

         3. In the case of documents and the information contained therein, designation of Confidential Information produced shall be made by placing the following legend on the face of the document and each page so designated "CONFIDENTIAL" or otherwise expressly identified as confidential. Defendant will use its best efforts to limit the number of documents designated Confidential.

         4. Confidential Information shall be held in confidence by each qualified recipient to whom it is disclosed, shall be used only for purposes of this action, shall not be used for any business purpose, and shall not be disclosed to any person who is not a qualified recipient. All produced Confidential Information shall be carefully maintained so as to preclude access by persons who are not qualified recipients.

         5. Qualified recipients shall include only the following:

(a) In-house counsel and law firms for each party and the secretarial, clerical and ...

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