Abdullah v. Wal-Mart Stores, Inc.

Filing 11

ORDER Granting 7 Stipulated Protective Order. Signed by Magistrate Judge Cam Ferenbach on 11/9/17. (Copies have been distributed pursuant to the NEF - ADR)

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1 2 3 4 5 6 7 8 9 ROBERT K. PHILLIPS Nevada Bar No. 11441 BETSY C. JEFFERIS Nevada Bar No. 12980 PHILLIPS, SPALLAS & ANGSTADT LLC 504 South Ninth Street Las Vegas, Nevada 89101 (702) 938-1510 (702) 938-1511 (Fax) rphillips@psalaw.net bjefferis@psalaw.net Attorneys for Defendant Wal-Mart Stores, Inc. UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 10 11 SADIYYAH ABDULLAH, 12 Case No.: 2:17-cv-02647-GMN-VCF Plaintiff, 13 14 STIPULATED PROTECTIVE ORDER BETWEEN PLAINTIFF SADIYYAH ABDULLAH AND DEFENDANT WALMART STORES, INC. v. WAL-MART STORES INC.; DOES I-X, inclusive, and ROE CORPORATIONS I-X, inclusive, 15 Defendants. 16 17 18 STIPULATED PROTECTIVE ORDER 19 20 The parties to this action, Defendant Wal-Mart Stores, Inc. and Plaintiff Sadiyyah Abdullah, 21 by their respective counsel, hereby stipulate and request that the Court enter a stipulated protective 22 order as follows: 23 24 1. The Protective Order shall be entered pursuant to the Federal Rules of Civil Procedure and applicable local rules for the United States District Court, District of Nevada 25 2. The Protective Order shall govern all materials agreed upon as “Confidential” by the 26 27 28 parties. Disclosed materials agreed to be confidential in nature shall be designated in writing as “Confidential,” and such designation may appear on the face each document or in a separate writing. -1- 1 The parties hereby agree that maps/schematics of the subject Walmart store, including 2 maps/schematics pertaining to the placement of surveillance cameras shall be Confidential. 3 3. Confidential Information shall be held in confidence by each party or his or her 4 representatives, attorneys, and agents for use solely for the purposes of this action and not for any 5 6 business purpose. Documents designated as confidential may not be disclosed to persons or parties 7 whose relationship to the dispute between the parties is not reasonably related to the prosecution or 8 defense of claims litigated. 9 10 11 4. Each counsel shall be responsible for providing notice of the Protective Order and the terms therein to persons to whom they disclose “Confidential” information as defined by the terms of the Protective Order. 12 5. 13 14 15 Confidential materials included in any papers, motions, or pleadings to avoid the public disclosure of said information. 16 17 18 The parties will comply with Local Rule IA 10-5 and seek to file under seal any 6. The termination of this action shall not relieve the parties and persons obligated hereunder from their responsibility to maintain the confidentiality of information designated confidential pursuant to this Order. 19 7. After the final adjudication or resolution of this Lawsuit (“final adjudication” will 20 21 include the resolution of any appeals), a party may make a written demand to the other party for the 22 return of confidential materials, including all copies and reproductions thereof. The party receiving the 23 written demand shall have thirty (30) days from receipt of the written demand to comply with same. 24 // 25 // 26 // 27 // 28 -2- 1 2 8. Nothing in the Protective Order shall be deemed to preclude any party from seeking and obtaining, on an appropriate showing, a modification of this Order. 3 4 DATED: November 3, 2017 DATED: November 3, 2017 5 6 /s/ David M. Menocal /s/ Betsy C. Jefferis 7 David M. Menocal Nevada Bar No. 13191 DECASTROVERDE LAW GROUP 1149 S. Maryland Pkwy Las Vegas, NV 89104 Attorneys for Plaintiff Sadiyyah Abdullah Betsy C. Jefferis Nevada Bar No. 12980 PHILLIPS, SPALLAS & ANGSTADT, LLC 504 South Ninth Street Las Vegas, Nevada 89101 Attorneys for Defendant Wal-Mart Stores, Inc. 8 9 10 11 12 The terms of the above stipulation for a protective order by and between Defendant Wal-Mart 13 Stores, Inc. and Plaintiff Sadiyyah Abdullah, by their respective counsel, shall hereby be the ORDER 14 of this Court. 15 9th November DATED this ____ day of ______________, 2017 16 _____________________________________ 17 UNITED STATES MAGISTRATE JUDGE 18 19 20 21 22 23 24 25 26 27 28 -3-

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