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Preston v. Target Corp.

February 12, 2010

CHRISTA J. PRESTON, PLAINTIFF,
v.
TARGET CORPORATION AND DOES 1 TO 25, DEFENDANTS.



The opinion of the court was delivered by: Marc L. Goldman United States Magistrate Judge

ORDER RE STIPULATED PROTECTIVE ORDER

Complaint Filed: May 27, 2009 Trial Date: September 14, 2010

IT IS HEREBY STIPULATED AND AGREED, by the undersigned attorneys for the respective parties, that with regard to material disclosed in the course of the above-captioned lawsuit ("Lawsuit") which constitutes or contains trade secrets or other confidential research, development or commercial information of the parties ("Confidential Material"), the following procedures shall govern:

1. This Order is meant to encompass all forms of disclosure which may contain Confidential Material, including all documents, pleadings, motions, exhibits, declarations, affidavits, deposition transcripts, inspection reports, and all other tangible items (electronic media, photographs, videocassettes, etc.) For purposes of this Stipulated Protective Order Confidential Material is specifically defined as follows:

1. Team Member Handbook ("Welcome to Team Target") eff. January 2007 to Present (Hourly);

2. Team Member Handbook eff. January 2007 to Present (Executive);

3. Spill Clean Up Procedures eff. May 2003 to Present;

4. New Team Member Orientation - DVD - eff. 02/2007 to 01/2008 ;

5. Floor Brand Maintenance Guide eff. 02/2007 to 01/2-008 #665765;

6. Cart Attendant Training - DVD - eff. 02/2004 through 02/2007;

7. Garden Place - Master Manual;

8. Garden Center Manual;

9. Watering Plants in the Garden Center;

10. Using Your Garden Center ...


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