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.

Brown v. Wal-Mart Stores, Inc.

United States District Court, D. Nevada

August 31, 2017

CHRISTINA BROWN, individually, Plaintiff,
v.
WAL-MART STORES, INC., a foreign corporation, DOES I through XX, and ROE CORPORATIONS I through XX, inclusive, Defendants.

          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.

         STIPULATED PROTECTIVE ORDER

         The 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 follows:

         1. The Protective Order shall be entered pursuant to Federal Rules of Civil Procedure (“FRCP”).

         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 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 contractor;
(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.

         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 be carefully maintained so as to preclude access by persons who are not qualified recipients.

         5. Qualified recipients shall include only the following:

(a) In-house counsel and law firms for each party and the secretarial, clerical and ...

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.