United States District Court, D. Nevada
BERNSTEIN & POISSON SCOTT L. POISSON, ESQ., BRIAN M.
BOYER, ESQ., Attorneys for Plaintiff' Tyrone Jackson
PHILLIPS, SPALLAS & ANGSTADT LLC, ROBERT K. PHILLIPS,
ESQ., MICHAEL A. ARATA, ESQ., Attorneys for Defendant.
Wal-Mart Stores, Inc.
STIPULATED PROTECTIVE ORDER BETWEEN PLAINTIFF TYRONE
JACKSON AND DEFENDANT WAL-MART STORES, INC.
parties to this action, Defendant WAL-MART STORES, INC.
("Walmart" or "Defendant") and Plaintiff
TYRONE JACKSON ("Plaintiff") (collectively, the
"Parties"), 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 Procedure.
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 (1) identifying said documents as confidential in
Defendant's FRCP 26(a) disclosures; (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 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 ...