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Robinson v. Wal-Mart Stores

July 9, 2009

SCOTT ROBINSON, AN INDIVIDUAL, PLAINTIFF,
v.
WAL-MART STORES, INC., A CORPORATION, DBA WAL-MART; AND DOES 1-100, INCLUSIVE, DEFENDANTS.



The opinion of the court was delivered by: Rosalyn M. Chapman Magistrate Judge of the United States District Court in the Central District of California

DISCOVERY MATTER [PROPOSED] PROTECTIVE ORDER

State Court Complaint Filed: February 26, 2009

NOTE: CHANGES MADE BY THE COURT

[PROPOSED] ORDER

UPON STIPULATION of the Parties, and For Good Cause Shown, IT IS HEREBY ORDERED:

1. That good cause exists for the Court to grant the Parties' Stipulation for Protective Order, filed concurrently herewith, that the parties to this action, Defendant Wal-Mart Stores, Inc. ("Wal-Mart" or "Defendant") and Plaintiff Scott Robinson ("Robinson" or "Plaintiff") (collectively "the Parties"), by their respective counsel, have stipulated and requested that the Court enter a mutual protective order pursuant to Fed. R. Civ. P. 26.

2. The Protective Order shall be entered pursuant to the Federal Rules of Civil Procedure.

3. 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, specifically including documents from Plaintiff's personnel, medical, and/or workers' compensation files;

(c) Any documents relating to the medical and/or health information of any of Defendant's current or former employees or contractors, specifically including documents relating to the medical and/or health information of Plaintiff;

(d) Any portions of depositions (audio or video) where Confidential Information is disclosed or used as exhibits.

4. In the case of documents and the information contained therein, designation of Confidential Information produced shall be made by placing the following legend on the face of the document and each page so designated "CONFIDENTIAL" or otherwise expressly identified as confidential. Defendant will use its best efforts to limit the number of documents designated Confidential.

5. 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 ...


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