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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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
[phone]
[phone] (Fax)
[e-mail]
[e-mail]
Attorneys for Defendant
Wal-Mart Stores, Inc.
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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SADIYYAH ABDULLAH,

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Case No.: 2:17-cv-02647-GMN-VCF

Plaintiff,

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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,

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Defendants.

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STIPULATED PROTECTIVE ORDER

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The parties to this action, Defendant Wal-Mart Stores, Inc. and Plaintiff Sadiyyah Abdullah,

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by their respective counsel, hereby stipulate and request that the Court enter a stipulated protective

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order as follows:

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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

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2.

The Protective Order shall govern all materials agreed upon as “Confidential” by the

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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.

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The parties hereby agree that maps/schematics of the subject Walmart store, including

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maps/schematics pertaining to the placement of surveillance cameras shall be Confidential.

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3.

Confidential Information shall be held in confidence by each party or his or her

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representatives, attorneys, and agents for use solely for the purposes of this action and not for any
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business purpose. Documents designated as confidential may not be disclosed to persons or parties

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whose relationship to the dispute between the parties is not reasonably related to the prosecution or

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defense of claims litigated.

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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.

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5.

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Confidential materials included in any papers, motions, or pleadings to avoid the public disclosure of
said information.

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The parties will comply with Local Rule IA 10-5 and seek to file under seal any

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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.

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7.

After the final adjudication or resolution of this Lawsuit (“final adjudication” will

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include the resolution of any appeals), a party may make a written demand to the other party for the

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return of confidential materials, including all copies and reproductions thereof. The party receiving the

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written demand shall have thirty (30) days from receipt of the written demand to comply with same.

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//

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//

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//

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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.

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DATED: November 3, 2017

DATED: November 3, 2017

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/s/ David M. Menocal

/s/ Betsy C. Jefferis

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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.

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The terms of the above stipulation for a protective order by and between Defendant Wal-Mart

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Stores, Inc. and Plaintiff Sadiyyah Abdullah, by their respective counsel, shall hereby be the ORDER

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of this Court.

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9th
November
DATED this ____ day of ______________, 2017

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_____________________________________

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UNITED STATES MAGISTRATE JUDGE
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