Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Stanley v. Petco Animal Supplies Inc.

United States District Court, D. Nevada

April 11, 2017

BRITTANY STANLEY, Plaintiff,
v.
PETCO ANIMAL SUPPLIES STORES, INC., a Delaware Corporation, Defendant.

          ANGELA J. LIZADA, ESQ. LIZADA LAW FIRM, LTD. Attorney for Plaintiff BRITTANY STANLEY.

          RICK D. ROSKELLEY, ESQ. TIMOTHY W. ROEHRS, ESQ. LITTLER MENDELSON, P.C. Attorneys for Defendant PETCO ANIMAL SUPPLIES STORE, INC.

          STIPULATED PROTECTIVE ORDER

         IT IS HEREBY STIPULATED, by and between the parties, by and through their respective counsel of record, that in order to protect the confidentiality of confidential information obtained by the parties in connection with this case, the parties agree as follows:

         1. Any party may designate as “confidential” (by stamping the relevant page or labeling the item or as otherwise set forth herein) any item, document or response to discovery which that party considers in good faith to contain information involving: personal and confidential information of third-parties or non-parties; trade secrets; or sensitive or confidential business or financial information of the parties, subject to protection under the Federal Rules of Civil Procedure or Nevada law (“Confidential Information”). The parties agree that Confidential Information specifically includes but is not limited to documents or items related to pet incidents, including the incident involving a cat's death on May 20, 2015 at the Petco store that Plaintiff formerly worked at, non-party Petco employee file documents and information, and Defendant's policy documentation. Where a document or response consists of more than one page, the first page and each page on which confidential information appears shall be so designated.

         2. A party may designate documents, items, or information disclosed during a deposition, in response to written discovery as “confidential” by so indicating in said response or on the record at the deposition and requesting the preparation of a separate transcript of such material. Additionally a party may designate in writing, within twenty (20) days after receipt of said responses or of the deposition transcript for which the designation is proposed, that specific pages of the transcript and/or specific responses be treated as “confidential” information. Any other party may object to such proposal, in writing or on the record. Upon such objection, the parties shall follow the procedures described in paragraph 8 below. After any designation made according to the procedure set forth in this paragraph, the designated documents or information shall be treated according to the designation until the matter is resolved according to the procedures described in paragraph 8 below, and counsel for all parties shall be responsible for making all previously unmarked copies of the designated material in their possession or control with the specified designation.

         3. All Confidential Information produced or exchanged in the course of this case (other than information that is publicly available) shall be used by the party to whom the information is produced solely for the purpose of this case.

         4. Except with the prior written consent of other parties, or upon prior order of this Court obtained upon notice to opposing counsel, Confidential Information shall not be disclosed to any person other than:

(a) counsel for the respective parties to this litigation, including in-house counsel and co-counsel retained for this litigation;
(b) employees of such counsel;
(c) individual defendants, class representatives, any officer or employee of a party, to the extent deemed necessary by Counsel for the prosecution or defense of this litigation;
(d) consultants or expert witnesses retained for the prosecution or defense of this litigation, provided that each such person shall execute a copy of the Certification annexed to this Order as Exhibit "A" (which shall be retained by counsel to the party so disclosing the Confidential Information and made available for inspection by opposing counsel during the pendency or after the termination of the action only upon good cause shown and upon order of the Court) before being shown or given any Confidential Information;
(e) any authors or recipients of the Confidential Information;
(f) the Court, Court personnel, and court reporters; and
(g) witnesses (other than persons described in paragraph 4(e)). A witness shall sign the Exhibit A Certification before being shown a confidential document. Confidential Information may be disclosed to a witness who will not sign the Certification only in a deposition at which the party who designated the Confidential Information is represented or has been given notice that Confidential Information shall be designated "Confidential" pursuant to ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.