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Roberts v. Walmart Stores East, LP

United States District Court, D. Nevada

June 19, 2019

JOYCE ANN ROBERTS, an individual, Plaintiff,
v.
WALMART STORES EAST, LP, a Foreign Limited Partnership; WALMART, INC., a Foreign Corporation; ART MARTINEZ; DOE STORE MANAGERS I through X; DOE STORE EMPLOYEES I through X; DOE OWNERS I through X; DOE PROPERTY MANAGERS I through X; DOE MAINTENANCE EMPLOYEES I through X; DOE JANITORIAL I through X; ROE PROPERTY MANAGERS XI through XX; ROE MAINTENANCE COMPANIES XI through XX; ROE OWNERS XI through XX; ROE EMPLOYERS XI through XX; and DOES XXI through XXV; and ROE CORPORATIONS XXV through XXX, inclusive, jointly and severally, Defendants.

          ROBERT K. PHILLIPS, ESQ. Nevada Bar No. 11441 MEGAN E. WESSEL, ESQ. Nevada Bar No. 14131 PHILLIPS, SPALLAS & ANGSTADT LLC Attorneys for Defendant Walmart, Inc. and Walmart Stores East, LP

          BIGHORN LAW KIMBALL JONES, ESQ. Nevada Bar No. 12982 Attorneys for Plaintiff Joyce Ann Roberts

          STIPULATED PROTECTIVE ORDER BETWEEN PLAINTIFF JOYCE ANN ROBERTS AND DEFENDANT WALMART, INC. AND WALMART STORES EAST LP

         The parties to this action, Defendant WALMART, INC. and WALMART STORES EAST, LP ("Walmart" or "Defendants") and Plaintiff JOYCE ANN ROBERTS ("Plaintiff) (collectively, the "Parties"), by 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 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 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 (1) identifying said documents as confidential in Defendant's FRCP 26(a) disclosures and any supplements made thereto; (2) placing the following legend on the face of the document and each page so designated "CONFIDENTIAL;" or (3) otherwise expressly identified as confidential via written correspondence. Defendant will use its best efforts to limit the No. 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 ...

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