United States District Court, D. Nevada
OFFICES OF STEVEN M. BURRIS STEVEN M. BURRIS, ESQ. Nevada Bar
No. 603 MICHAEL A, KONING, ESQ. Attorneys for
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.
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:
Protective Order shall be entered pursuant to the Federal
Rules of Civil Procedure.
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
(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.
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 ...