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Brown v. SAM'S West, Inc.

United States District Court, D. Nevada

June 5, 2017

KEVIN BROWN, an individual, JENNIFER BROWN, an individual; Plaintiff,
v.
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 Plaintiffs.

          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, LLC

         STIPULATED PROTECTIVE ORDER

         The 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:

         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 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.

         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 ...


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