Trina Hayes v. Wal-Mart Associates, Inc. et al
Filing
17
STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION by Magistrate Judge Patricia Donahue re Stipulation for Protective Order #16 . (see document for details.) (et)
1 Seung Yang CA Bar No. 249857
seung.yang@thesentinelfirm.com
2 Brett M. Gunther CA Bar No. 306448
brett.gunther@thesentinelfirm.com
3 Emily Rivadeneira CA Bar No. 354395
emily.rivadeneira@thesentinelfirm.com
4 THE SENTINEL FIRM, APC
355 S. Grand Ave., Suite 1450
5 Los Angeles, CA 90071
Telephone: 213-985-1150
213-985-2155
6 Facsimile:
7 Attorneys for Plaintiff
8
TRINA HAYES
James T. Conley CA Bar No. 224174
9 james.conley@ogletree.com
Michele J. Bongiovanni Bar No. 309884
10 michele.bongiovanni@ogletree.com
Sandra Benlevy Bar No. 211568
11 sandra.benlevy@ogletree.com
OGLETREE, DEAKINS, NASH,
12 SMOAK & STEWART, P.C.
400 Capitol Mall, Suite 2800
13 Sacramento, CA 95814
Telephone: 916-840-3150
916-840-3159
14 Facsimile:
15 Attorneys for Defendant
16
WAL-MART ASSOCIATES, INC.
UNITED STATES DISTRICT COURT
17
CENTRAL DISTRICT OF CALIFORNIA
18
19
20
21
22
TRINA HAYES,
Case No. 5:24-cv-01856-JLS-PD
Plaintiff,
v.
WAL-MART ASSOCIATES, INC., a
23 corporation; and DOES 1-25, inclusive,
24
STIPULATION REGARDING
PRODUCTION OF CONFIDENTIAL
DOCUMENTS AND PROPRIETARY
INFORMATION; [PROPOSED]
ORDER
Defendant.
25
26
27
28
Case No. 5:24-cv-01856-JLS-PD
STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL
DOCUMENTS AND PROPRIETARY INFORMATION; ORDER
1
IT IS HEREBY STIPULATED by and between Plaintiff TRINA HAYES
2
(“Plaintiff”) and Defendant WAL-MART ASSOCIATES, INC., (“Defendant”)
3
(collectively, “the Parties”), through their respective attorneys of record, that a
4
Protective Order be entered by this Court as follows:
1.
5
This Stipulation and Protective Order shall apply to the production and
6
exchange of all document requests and documents, interrogatories and answers to
7
interrogatories, depositions, request for admissions and responses to requests for
8
admissions, exhibits, pleadings, admission of evidence at trial, and all other
9
information exchanged and furnished in this action by the Parties that are confidential
10
and/or proprietary.
2.
11
The Parties acknowledge that discovery will require disclosure of
12
information that is private, personal, privileged, confidential, proprietary, or
13
nonpublic. As a result, the Parties agree that they will be required to enter this
14
Stipulation and Protective Order (hereinafter “Order”) on the following terms to
15
ensure the continuing confidentiality of materials designated as Confidential Material
16
in this litigation. Confidential Material, as used in this Order, shall refer to any
17
document or item designated as “Confidential” or “Highly Confidential – Attorneys’
18
Eyes Only”. The Parties understand that this Order does not confer blanket protections
19
on all disclosures or responses to discovery and that the protection it affords extends
20
only to the limited information or items that are entitled under the applicable legal
21
principles to treatment as confidential. Nothing in this Order shall require any party to
22
produce any specific document or category of documents which a party deems
23
inappropriate for production.
24
I.
25
26
27
28
Definitions of Confidential Material
3.
Confidential Material, as used in this Order, consists of the following
materials and categories of materials:
(a)
Materials relating to any privileged, confidential, or nonpublic
information, including, but not limited to, trade secrets, research, design,
1
Case No. 5:24-cv-01856-JLS-PD
STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL
DOCUMENTS AND PROPRIETARY INFORMATION; ORDER
64132503.v1-OGLETREE
1
development, financial, technical, marketing, planning, personal, or commercial
2
information, as such terms are used in the Federal Rules of Civil Procedure and
3
any applicable case law interpreting Federal Rule of Civil Procedure
4
26(c)(1)(G), contracts, non-public compilations of retail prices; proprietary
5
information, vendor agreements; personnel files; claim/litigation information;
6
nonpublic policies and procedures; medical records; employment offers;
7
competitive analyses, income statements; client or customer information;
8
financial records and statements; vendor agreements, along with other
9
proprietary or confidential information.
(b)
10
Materials containing corporate trade secrets, nonpublic research
11
and development data, including, but not limited to, cost data, pricing formulas,
12
inventory management programs, and other sales or business information
13
known to the public; information obtained from a non-party pursuant to a non-
14
disclosure agreement; and customer-related Protected Data shall be deemed
15
“Highly Confidential – Attorneys’ Eyes Only”.
(c)
16
“Protected Data” shall refer to any information that a party believes
17
in good faith to be subject to federal, state or foreign data protection laws or
18
other privacy obligations. Examples of such data protection laws include but are
19
not limited to The Gramm-Leach-Bliley Act, 15 U.S.C. § 6801 et seq. (financial
20
information); and, The Health Insurance Portability and Accountability Act and
21
the regulations thereunder, 45 CFR Part 160 and Subparts A and E of Part 164
22
(medical information). Certain Protected Data may compel alternative or
23
additional protections beyond those afforded “Highly Confidential – Attorneys’
24
Eyes Only” material, in which event the Parties shall meet and confer in good
25
faith, and, if unsuccessful, shall move the Court for appropriate relief.
26
4.
27
28
The Parties shall not designate as confidential information that is already
public knowledge.
2
Case No. 5:24-cv-01856-JLS-PD
STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL
DOCUMENTS AND PROPRIETARY INFORMATION; ORDER
5.
1
The Parties agree that such Confidential Material as described in
2
paragraph 3 above, should be given the protection of an order of this Court to prevent
3
injury through disclosure to persons other than those persons involved in the
4
prosecution or defense of this litigation. A Protective Order will serve to achieve the
5
following: expedite the flow of information, facilitate the prompt resolution of disputes
6
over confidentiality of discovery materials, adequately protect information the Parties
7
are entitled to keep confidential, ensure that the Parties are permitted reasonable
8 necessary uses of such material in preparation for and in the conduct of trial, and
9 address their handling at the end of the litigation.
10
11
II.
Procedure for Designating Information as Confidential
6.
To designate information as confidential, the producing party shall mark
12
Confidential Material with the legend “CONFIDENTIAL” or “HIGHLY
13
CONFIDENTIAL – ATTORNEYS’ EYES ONLY”. Parties shall submit confidential
14 discovery responses, such as answers to interrogatories or answers to requests for
15 admissions, in a separate document stamped with the appropriate legend designating
16 those responses as Confidential Material. The Receiving Party may make copies of
17 Confidential Material and such copies shall become subject to the same protections as
18 the Confidential Material from which those copies were made.
19
(a)
Information on a disk or other electronic format (e.g., a native
20
format production) may be designated confidential by marking the storage
21
medium itself (or the native file’s title) with the legend “CONFIDENTIAL” or
22
“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”. The Receiving
23
Party shall mark any hard-copy printouts and the storage medium of any
24
permissible copies of such electronic material with the corresponding legend
25
contained on the original and such copies shall become subject to the same
26
protections, as the Confidential Material from which those copies were made.
27
(b) Information disclosed at any deposition of a party taken in this
28
action may be designated by the party as confidential by indicating on the record
3
Case No. 5:24-cv-01856-JLS-PD
STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL
DOCUMENTS AND PROPRIETARY INFORMATION; ORDER
1
at the deposition that the information is confidential and subject to the
2
provisions of this Order. Alternatively, the party may designate information
3
disclosed at the deposition as confidential by notifying the court reporter and
4
other parties in writing, within fifteen (15) business days of receipt of the
5
transcript, of the specific pages and lines of the transcript which are designated
6
as confidential. The Parties may agree to a reasonable extension of the 15-
7
business-day period for designation. Designations of transcripts will apply to
8
audio, video, or other recordings of the testimony. During such 15-business-
9
day period, the entire transcript shall receive confidential treatment. Upon such
10
designation,
the
court
reporter
and
each
party
shall
affix
the
11
“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
12
ONLY” legend to the designated pages and segregate them as appropriate.
13
7.
A producing party may change the confidentiality designation of
14
materials it has produced, as follows: (1) The producing party must give the receiving
15
parties notice of the change by identifying the documents or information at issue. Once
16
notice is given, the receiving party must make good-faith efforts to ensure that the
17
documents or information are accorded treatment under the new designation. (2)
18
Within a reasonable period after giving notice, the producing party must reproduce the
19
documents or information in a format that contains the new designation. (3) If such
20
information has been disclosed to persons not qualified pursuant to paragraph(s) (14-
21
15) below, the party who disclosed such information shall (a) take reasonable efforts
22
to retrieve previously disclosed Confidential Material; (b) advise such persons that the
23
material is Confidential; and (c) give the producing party written assurance that steps
24
(a) and (b) have been completed.
25
III.
26
Data Security
8.
The Parties agree to provide adequate security to protect data produced
27
by the other party(ies) or by non-parties. This includes secure data storage systems,
28
established security policies, and security training for employees, contractors and
4
Case No. 5:24-cv-01856-JLS-PD
STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL
DOCUMENTS AND PROPRIETARY INFORMATION; ORDER
1
experts. Adequate security also includes such measures as data encryption in transit,
2
data encryption at rest, data access controls, and physical security, whether
3
hosted/outsourced to a vendor or on premises. At a minimum, any receiving party
4
subject to the terms of this Order, will provide reasonable measures to protect non-
5
client data consistent with the American Bar Association Standing Committee on
6
Ethics and Professional Responsibility, Formal Opinion 477R.
7
IV.
8
Clawback Provisions
9.
The production of privileged or work-product protected documents,
9
electronically stored information (ESI) or information, whether inadvertent or
10
otherwise, is not a waiver of the privilege or protection from discovery in this case or
11
in any other federal or state proceeding.
12
10.
This Order shall be interpreted to provide the maximum protection
13
allowed by Federal Rule of Evidence (FRE) 502(d) and shall be enforceable and
14
granted full faith and credit in all other state and federal proceedings by 28 U.S. Code
15
§ 1738. In the event of any subsequent conflict of law, the law that is most protective
16
of privilege and work product shall apply.
17
11.
Nothing contained herein is intended to or shall serve to limit a party’s
18
right to conduct a review of documents, ESI or information (including metadata) for
19
relevance, responsiveness and/or segregation of privileged and/or protected
20
information before production.
21
12.
If the receiving party has reason to believe that a produced document or
22
other information may reasonably be subject to a claim of privilege, then the receiving
23
party shall immediately sequester the document or information, cease using the
24
document or information and cease using any work product containing the
25
information, and shall inform the producing party of the beginning BATES number of
26
the document or, if no BATES number is available, shall otherwise inform the
27
producing party of the information.
28
5
Case No. 5:24-cv-01856-JLS-PD
STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL
DOCUMENTS AND PROPRIETARY INFORMATION; ORDER
13.
1
A producing party must give written notice to any receiving party
2
asserting a claim of privilege, work-product protection, or other ground for reclaiming
3
documents or information (a “clawback request”).
4
received, the receiving party shall immediately sequester the document (if not already
5
sequestered) and shall not review or use that document, or any work product
6
containing information taken from that document, for any purpose. The Parties shall
7
meet and confer regarding any clawback request.
8
V.
9
After a clawback request is
Who May Receive Confidential and Highly Confidential Information
14.
Confidential Material. Any Confidential Material and the information
10 contained therein shall be disclosed only to the Court, its staff, in-house counsel and
11
outside counsel of record for each party, and also shall be disclosed on a need-to-know
12
basis only to the Parties, counsel’s staff personnel, employees of a party to whom
13
disclosure is necessary in connection with the preparation for and trial of this action,
14
and any witnesses in the case (including consulting and testifying experts) as may from
15
time to time reasonably be necessary in prosecution or defense of this action.
16
15.
Highly Confidential—Attorneys’ Eyes Only Material. Material and
17
information designated as “Highly Confidential—Attorneys’ Eyes Only” shall only be
18
disclosed to the Court, its staff, in-house and outside counsel of record for each party,
19
the secretarial, clerical, and paralegal staff of each, and consulting and testifying
20
experts retained by a party in this action.
21
16.
Restriction on Disclosure to Direct Competitors. Notwithstanding the
22
foregoing, Confidential Material shall not be disclosed to any current or former
23
employees of, or current or former consultants, advisors, or agents of, a direct
24
competitor of any party named in the litigation. If a Receiving Party is in doubt about
25
whether a particular entity is a direct competitor of a party named in this lawsuit, then
26
before disclosing any Confidential Material to a current or former employee,
27
consultant, advisor, or agent of that entity, the Receiving Party’s counsel must confer
28
with counsel for the Producing Party.
6
Case No. 5:24-cv-01856-JLS-PD
STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL
DOCUMENTS AND PROPRIETARY INFORMATION; ORDER
17.
1
Persons Receiving Confidential Information Must Sign Exhibit A.
2
Counsel for each party shall advise all persons to whom Confidential Material is
3
disclosed pursuant to this Order of the existence of this Order and shall provide all
4
such persons (other than the Court and its staff) with a copy of this Order. Counsel
5
shall also require such persons to execute the Affidavit attached as Exhibit A, prior to
6
the disclosure of Confidential Material.
18.
7
Duties in the Event of Unauthorized Disclosures.
It shall be the
8
obligation of counsel, upon learning of any unauthorized disclosure or threatened
9
unauthorized disclosure of Confidential Information, or any other breach or threatened
10
breach of the provisions of this Order, to promptly notify counsel for the Producing
11
Party.
12
circumstances of the disclosure in order to permit the producing party to understand
13
and take appropriate steps. Each party and its counsel agree to take reasonable and
14
good-faith efforts to contain or limit any breach promptly upon receiving notice of it,
15
and to make reasonable and good-faith attempts to retrieve any unauthorized
16
disclosure of documents or information. This provision does not limit the producing
17
party’s entitlement to damages resulting from any breach of this Order.
18
VI.
Authorized Uses of Confidential Material
19.
19
20
The notification shall be supplemented with reasonable details of the
Confidential Material shall only be used for the purpose of litigating the
above-captioned lawsuit and may not be used in other lawsuits.
20.
21
Persons having knowledge of Confidential Material and information due
22
to their participation in the conduct of this litigation shall use such knowledge and
23
information only as
24
permitted herein, and shall not disclose such Confidential Material, their contents or
25
any portion or summary thereof to any person(s) not involved in the conduct of this
26
litigation.
27
///
28
///
7
Case No. 5:24-cv-01856-JLS-PD
STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL
DOCUMENTS AND PROPRIETARY INFORMATION; ORDER
21.
1
If any person having access to the Confidential Material herein shall
2
violate this Order, he/she may be subject to sanctions by the Court and may be liable
3
to pay for the damages caused by his/her violation.
4
VII. Challenges to the Designation of Confidential Material
22.
5
Any party or interested member of the public may move the Court to
6
modify the designation of any documents or information produced in this litigation
7
(either to include additional protection with respect to confidentiality or to remove a
8
confidential designation). Before making such a motion, the party or an interested
9
member of the public shall first attempt to resolve such dispute with the producing
10
party’s counsel. Pending resolution of any challenges to the designation of documents
11
or information, the material at issue shall continue to be treated as Confidential
12
Material until ordered otherwise by the Court. The burden shall be on the party
13
seeking to modify the designation to show that the producing party’s designation is
14
inappropriate.
15
VIII. Withholding of Information
23.
16
Redactions. The Parties may redact (1) information that is privileged or
17
protected from discovery as work product or by reason of any other applicable
18
privilege or immunity; (2) information subject to non-disclosure obligations imposed
19
by governmental authorities, law or regulation (e.g., protected personal information);
20
and (3) sensitive, non-relevant information, including but not limited to personally
21
identifiable information, trade secrets, or information regarding products, data, or
22
people. Redactions of emails will not redact the names of recipients or the subject line
23
of the emails, unless the subject line is itself privileged or contains the sensitive
24
information described above, in which case only so much of the subject line will be
25
redacted as may be needed. The Parties will produce redacted documents in TIFF
26
format (or searchable PDF if production format dictates; or in native format for file
27
types that do not convert well to TIFF/PDF, such as Excel files) with corresponding
28
///
8
Case No. 5:24-cv-01856-JLS-PD
STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL
DOCUMENTS AND PROPRIETARY INFORMATION; ORDER
1
searchable OCR text and the associated metadata for the document, ensuring the
2
redacted content is fully protected from disclosure.
3
IX.
4
Confidential Material In Filings, Hearings, and Trial
24.
Confidential Material in Filings. Without written permission from the
5 Producing Party or court order secured after appropriate notice to all interested
6 persons, a party may not file Confidential Material in the public record in this action
7 (or in any other action, such as an appeal). A party that seeks to file under seal any
8 Confidential Material must first comply with Judge Staton’s General Procedures and
9 in compliance with Central District of California Local Rule 79-5. Confidential
10 Material may only be filed under seal in a manner prescribed by the Court for such
11 filings.
12
25.
Manner of Sealing. In the event Confidential Materials or portions of
13 transcripts are sealed as confidential by the Court or as described in paragraph (25)
14 above, they shall be filed in an envelope bearing the following designation when
15 deposited:
16
CONFIDENTIAL
17
IN ACCORDANCE WITH THE CONFIDENTIALITY
18
ORDER OF THE COURT, THE CONTENTS OF THIS
19
ENVELOPE SHALL BE TREATED AS CONFIDENTIAL
20
AND MUST NOT BE SHOWN TO A PERSON OTHER
21
THAN THE COURT, ATTORNEYS IN THIS CASE, OR
22
TO PERSONS ASSISTING THOSE ATTORNEYS.
23
26.
Confidential Material in Hearings and Trial. The provisions of this
24 Order shall not affect, and this Order does not limit, the admissibility of Confidential
25 Material (or references to that material) as evidence at trial, or during a hearing or
26 similar proceeding in this action.
Prior to using Confidential Material or the
27 information contained therein at any hearing that is open to the public, the party
28 seeking to use the Confidential Material must give at least seven (7) days advance
9
Case No. 5:24-cv-01856-JLS-PD
STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL
DOCUMENTS AND PROPRIETARY INFORMATION; ORDER
1
notice to the producing party of the intent to use the Confidential Material so that the
2
producing party may seek an appropriate Court Order to protect the Confidential
3
Material.
4
X.
Continuing Effect of this Order and Duty to Destroy
27.
5
This Order shall continue to be binding throughout and after the
6
conclusion of this litigation, including all appeals. Within thirty (30) days of settlement
7
or final adjudication, including the expiration or exhaustion of all rights to appeal or
8
petitions for extraordinary writs, each party or non-party to whom any materials were
9
produced shall, without further request or direction from the Producing Party,
10
promptly destroy all documents, items or data received including, but not limited to,
11
copies or summaries thereof, in the possession or control of any expert or employee.
12
This requirement to destroy includes all documents, not only those documents
13
designated as Confidential Material. The Receiving Party shall submit a written
14
certification to the Producing Party by the 30-day deadline that (1) confirms the
15
destruction/deletion of all Confidential Material, including any copies of Confidential
16
Materials provided to persons required to execute Exhibit A (Affidavit), and (2)
17
affirms the Receiving Party has not retained any copies, abstracts, compilations,
18
summaries or any other format reproducing or capturing any of the Confidential
19
Material. Notwithstanding this provision, outside counsel is entitled to retain an
20
archival copy of filings, depositions, and deposition exhibits.
21
XI.
22
Procedure if Confidential Material is Required to be Produced
28.
If any person receiving documents covered by this Order is served with a
23
subpoena, order, interrogatory, document, or civil investigative demand (collectively,
24
a “Demand”) issued in any other action, investigation, or proceeding, and such
25
Demand seeks material that was produced or designated as Confidential Material by
26
someone other than the Receiving Party, the Receiving Party shall give prompt written
27
notice by hand or electronic transmission within five (5) business days of receipt of
28
such Demand to the party or non-party who produced or designated the material as
10
Case No. 5:24-cv-01856-JLS-PD
STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL
DOCUMENTS AND PROPRIETARY INFORMATION; ORDER
1
Confidential Material, and shall object to the production of such materials on the
2
grounds of the existence of this Order. At the request of the party or non-party who
3
produced or designated the material as Confidential Material, the Receiving Party shall
4
refuse to comply with the Demand unless (a) ordered to do so by a court with
5
jurisdiction over the Receiving Party; or (b) released in writing by the party or non-
6
party who designated the material as Confidential Material. The burden of opposing
7
the enforcement of the Demand shall fall upon the party or non-party who produced
8
or designated the material as Confidential Material. Compliance by the Receiving
9
Party with any order of a court of competent jurisdiction, directing production of any
10
Confidential Material, shall not constitute a violation of this Order.
11 XII. Application of this Order to Productions by Third Parties
12
29.
This Order may be used by third parties producing documents in
13
connection with this action. Third parties may designate information as “Confidential”
14
or “Highly Confidential – Attorneys’ Eyes Only”.
15
30.
If a third party produces (or intends to produce) documents and does not
16
designate (or does not intend to designate) those documents as Confidential Material,
17
then any party to this action may seek to designate that third party’s documents or
18
categories of documents as Confidential Material. In that case, it will be the burden
19
of the party seeking protected status to move for a court order designating the materials
20
as Confidential Material after the Parties confer.
21
31.
In the event additional parties join or intervene in this litigation, the newly
22
joined party(ies) shall not have access to Confidential Material until its/their counsel
23
has executed and, at the request of any party, filed with the Court the agreement of
24
such party(ies) and such counsel to be fully bound by this Order.
25
32.
The Parties agree that nothing in this Order shall be deemed to limit the
26
extent to which counsel for the Parties may advise or represent their respective clients,
27
conduct discovery, prepare for trial, present proof at trial, including any document
28
designated Confidential Material as set forth herein, or oppose the production or
11
Case No. 5:24-cv-01856-JLS-PD
STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL
DOCUMENTS AND PROPRIETARY INFORMATION; ORDER
1
2
admissibility of any information or documents which have been requested.
33.
This Order shall remain in full force and effect until such time as it is
3
modified, amended, or rescinded by the Court.
4
XIII. No Admissions
5
34.
Neither entering into this Stipulation for Protective Order, nor receiving
6
any documents or other information designated as “Confidential,” shall be construed
7
as an agreement or admission (1) that any document or information designated as
8
“Confidential” is in fact Confidential Information; (2) as to the correctness or truth of
9
any allegation made or position taken relative to any matter designated as
10
“Confidential”; or (3) as to the authenticity, competency, relevancy, or materiality of
11
any information or document designated as “Confidential.”
12
XIV. Modification – Further Agreements
13
35.
Nothing contained herein shall preclude any party from seeking from the
14
Court, modification of this Stipulated Protective Order upon proper notice or shall
15
preclude the Parties from entering into other written agreements designed to protect
16
Confidential Information.
17
XV. Counterparts
18
36.
This Stipulation for Protective Order may be executed in counterparts,
19
each of which shall be deemed an original, and which together shall constitute one
20
instrument.
21
22
23
24
25
26
27
28
12
Case No. 5:24-cv-01856-JLS-PD
STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL
DOCUMENTS AND PROPRIETARY INFORMATION; ORDER
1
2
DATED: October 23, 2024
OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.
3
4
By: /s/ James T. Conley
James T. Conley
Michele J. Bongiovanni
Sandra Benlevy
Attorneys for Defendant
WAL-MART ASSOCIATES, INC.
5
6
7
8
9
DATED: October 23, 2024
THE SENTINEL FIRM, APC
10
11
By: /s/ Brett M. Gunther
Sueng Yang
Brett M. Gunther
Emily Rivadeneira
Attorneys for Plaintiff
TRINA HAYES
12
13
14
15
16
17
ATTESTATION – L.R. 5-4.3.4
18
I attest that all other signatories listed on this signature page, and on whose
19
behalf the filing is submitted, concur in the filing’s content and have authorized the
20
filing.
21
22
23
Date: October 23, 2024
By: /s/ James T. Conley
James T. Conley
24
25
26
27
28
13
Case No. 5:24-cv-01856-JLS-PD
STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL
DOCUMENTS AND PROPRIETARY INFORMATION; ORDER
ORDER
1
2
The Court has reviewed the Stipulation Regarding Production of Confidential
3
Documents and Proprietary Information filed by Defendant WAL-MART
4
ASSOCIATES, INC., (“Defendant”) and Plaintiff TRINA HAYES (“Plaintiff”)
5
(collectively, “the Parties”), through their counsel of record, requesting that the Court
6
enter an Order.
7
IT IS SO ORDERED.
8
9
DATED: _October 24, 2024
10
11
12
The Honorable Patricia Donahue
USDC, Central District of California
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Case No. 5:24-cv-01856-JLS-PD
STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL
DOCUMENTS AND PROPRIETARY INFORMATION; ORDER
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Exhibit A
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ACKNOWLEDGMENT OF RECEIPT OF PROTECTIVE ORDER
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REGARDING CONFIDENTIAL INFORMATION AND AGREEMENT TO
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BE BOUND THEREBY
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I hereby acknowledge receipt of and that I have read a copy of the Stipulation
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for Protective Order and Order (the “Order”), which I understand was made on
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_________________, 2024, in the action entitled Trina Hayes v. Wal-Mart Associates,
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Inc., United States District Court Central District of California, Case No. 5:24-cv-
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01856-JLS-PD. I agree that I will be bound by the provisions of the Order with respect
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to any Confidential Information provided to me under the terms thereof. I agree that,
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if I receive any Confidential Information, I will not make any copies thereof nor
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disclose such Confidential Information except as permitted by the Order. I further
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understand that if I fail to comply with the terms of the Order, I may be subject to
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sanctions by the Court, and I hereby consent to personal jurisdiction in the State of
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California with respect to any matter relating to or arising out of the Order.
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Executed this _____day of ________, 2024, at __________________, _____.
City
State
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_____________________________
Signature
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Name:
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Affiliation:
________________________________________
Address:
________________________________________
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________________________________________
________________________________________
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Case No. 5:24-cv-01856-JLS-PD
STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL
DOCUMENTS AND PROPRIETARY INFORMATION; ORDER
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