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Rosa v. Wal-Mart Stores, Inc.

United States District Court, D. Nevada

April 7, 2017

RITA ROSA, an individual, Plaintiff,
v.
WAL-MART STORES, INC., a foreign corporation, DOES I through X, individuals; and ROE CORPORATIONS I through X, Defendants.

          LAW OFFICES OF STEVEN M. BURRIS STEVEN M. BURRIS, ESQ. Nevada Bar No. 603 MICHAEL A, KONING, ESQ. Attorneys for Plaintiff

          PHILLIPS, SPALLAS & ANGSTADT LLC BRENDA H. ENTZMINGER, ESQ, Nevada Bar No. 9800 TIMOTHY D. KUHLS, ESQ. Attorneys for Defendant Wal-Mart Stores, Inc.

          STIPULATED PROTECTIVE ORDER BETWEEN PLAINTIFF, RITA ROSA AND DEFENDANT. WAL-MART STORES. INC. AS AMENDED ON P. 2

         The parties to this action, Defendant Wal-Mart Stores, Inc. ("Walmart" or "Defendant") and Plaintiff Rita Rosa, 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 Walmart 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 paralegal staff of each;
(b) Deposition notaries and staff;
(c) Persons other than legal counsel who have been retained or specially employed by a party as an expert witness for purposes of this lawsuit or to perform ...

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