United States District Court, D. Nevada
NETTLES LAW FIRM BRIAN D. NE1TLES, ESQ, Nevada Bar No. 7462
CHRISTIAN M. MORRIS, ESQ. Nevada Bar No. 11218 EDWARD J.
WYNDER, ESQ. Nevada Bar No. 13991 Attorneys for Plaintiff
PHILLIPS, SPALLAS & ANGSTADT LLC Timothy D Kuhls ROBERT
K. PHILLIPS, ESQ .. Nevada Bar No. 11441 TIMOTHY D. KUHLS,
ESQ. Nevada Bar No. 13362 Attorneys for Defendant Wal-Mart
Stores, Inc., et al.
STIPULATED PROTECTIVE ORDER BETWEEN PLAINTIFF ROBERT
FLORES AND DEFENDANTS WAL-MART STORES, INC. D/B/A WAL-MART
NEIGHBORHOOD MARKET NO. 3355 AND JONATHAN SOROLA
parties to this action, Plaintiff Robert Flores
("Plaintiff) and Defendants Wal-Mart Stores, Inc. d/b/a
Wal-Mart Neighborhood Market No. 3355 ("Wal-Mart")
and Jonathan Sorola ("Sorola") (collectively
"Defendants"), 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
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 Defendants' current or former personnel; policies,
procedures and/or training materials of Defendants and/or
Defendants' 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 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. Defendants
will use their 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 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 ...