United States District Court, D. Nevada
KEVIN BROWN, an individual, JENNIFER BROWN, an individual; Plaintiff,
SAM'S WEST, INC.; ADVANTAGE SALES AND MARKETING, LLC and DOES 1 through 100; Defendants.
CHRISTIANSEN LAW OFFICES PETER S: CHRISTIANSEN. ESQ., R. TODD
TERRY, ESQ., JUSTIN L. W ATKINS, ESQ. Attorneys for
PHILLIPS, SPALLAS & ANGSTADT LLC SUNEEL J. NELSON, ESQ.
Attorneys for Defendant Sam's West, Inc.
MURCHISON & CUMMING, LLP MICHAEL J. NUNEZ, ESQ. Attorneys
for Defendant Advantage Sales and Marketing, LLC.
STIPULATED PROTECTIVE ORDER BETWEEN DEFENDANT
SAM'S WEST, INC. PLAINTIFFS KEVIN BROWN AND JENNIFER
BROWN., AND DEFENDANT ADVANTAGE SALES AND MARKETING,
parties to this action, Defendant SAM'S WEST, INC.
("Sam's West"), Defendant ADVANTAGE SALES AND
MARKETING ("ASM"), and Plaintiffs KEVIN BROWN and
JENNIFER BROWN ("Plaintiffs"), by and through their
respective counsel, and hereby stipulate and request that the
Court enter a stipulated protective order as follows:
Protective Order shall be entered pursuant to the Federal
Rules of Civil Procedure.
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 current or former personnel of Defendants; policies,
procedures and/or training materials of Defendants and/or
Defendant's organizational structure;
(b) Any documents from the personnel, medical or workers'
compensation file of any of Defendants' current or former
employees or contractors;
(c) Any documents relating to the Plaintiffs' medical
and/or health information or that of any of Defendants'
current or former employees or contractors;
(d) Any portions of depositions (audio or video) where
Confidential Information is disclosed or used as exhibits.
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
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 ...