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Miriana Pozega-Walker, An Individual v. Target Corporation

May 13, 2011

MIRIANA POZEGA-WALKER, AN INDIVIDUAL, PLAINTIFF,
v.
TARGET CORPORATION, A BUSINESS ENTITY, FORM UNKNOWN, AND DOES 1 TO 100, INCLUSIVE, DEFENDANTS.



State Case No. MC022345

[PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER

Complaint Filed: 2/16/11 Trial: 2/7/12

IT IS HEREBY ORDERED, by the undersigned Judge of the District Court of the Central District of California, under the terms of the stipulation executed by the 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 eff. 2008/Jan. to Present (Executive);

2. Team Member Handbook ("Welcome to Team Target") eff. 2008/Jan. to Present (Hourly);

3. Spill Clean Up Procedures eff. May 2003 to Present; 4. New Team Member Orientation Script #679887 and DVD eff. 02/2008 to Present;

5. Floor Brand Maintenance Guide #668999 eff. 02/2008 to Present;

6. Cart Attendant Training DVD eff. 03/2007 to Present;

7. Guest Incident Investigation Kit.

2. The parties may designate any Confidential Material produced or filed in this Lawsuit as confidential and subject to the terms of this Order by marking such materials ("Confidential"). If any material has multiple pages, this designation need only be placed on the first page of such material. Any material designated as "Confidential" shall not be disclosed to any person or entity except to the parties, counsel for the respective parties, and expert witnesses assisting counsel in this Lawsuit, and the Court.

3. Any material designated as confidential pursuant to paragraph 2 above shall be used solely for the purposes of this Lawsuit and for no other purpose.

4. Prior to disclosure of any Confidential Material, each person to whom disclosure is to be made shall execute a written "Confidentiality Agreement" (in the form attached hereto) consenting to be bound by the terms of this Order. The parties, counsel for the respective parties (including legal assistants and other personnel) and the Court are deemed to be bound by this Order and are not required to execute a Confidentiality Agreement.

5. Only counsel of record in this Lawsuit shall be permitted to disseminate Confidential Material. Upon dissemination of any Confidential Material, each non-designating counsel of record in this Lawsuit shall maintain a written record as to: (1) the identity of any person given Confidential Material, and (2) the identity of the Confidential Material so disseminated (such as by ...


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