United States District Court, D. Nevada
PATERNOSTER LAW GROUP, LLC DUSTIN E. BIRCH, ESQ. Attorneys
for Plaintiff Christina Brown
PHILLIPS, SPALLAS & ANGSTADT, LLC POOJA KUMAR, ESQ.
Attorneys for Defendant Wal-Mart Stores, Inc.
STIPULATED PROTECTIVE ORDER BETWEEN PLAINTIFF
CHRISTINA BROWN AND DEFENDANT WAL-MART STORES, INC.
parties to this action, Defendant WAL-MART STORES, INC.
(hereinafter “Defendant”) and Plaintiff CHRISTINA
BROWN (hereinafter “Plaintiff”), by and through
their respective counsel, hereby stipulate and request that
the Court enter a stipulated protective order pursuant as
Protective Order shall be entered pursuant to Federal Rules
of Civil Procedure (“FRCP”).
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.
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.
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 ...