Opinion
Case No.: 2:12-cv-01907-RCJ-PAL
01-14-2013
RONALD PICARD, Plaintiff, v. WAL-MART STORES, INC. a Delaware Corporation; DOES I through V, inclusive, Defendants.
Siria L. Gutiérrez Nevada Bar No.11981 PHILLIPS, SPALLAS & ANGSTADT LLC Attorneys for Defendant Wal-Mart Stores, Inc. Keith E. Galliher, Jr., Esq. Christy Lyn M. Galliher-Gagliano, Esq. THE GALLIHER LAW FIRM Attorneys for Plaintiff
Siria L. Gutiérrez
Nevada Bar No.11981
PHILLIPS, SPALLAS & ANGSTADT LLC
Attorneys for Defendant
Wal-Mart Stores, Inc.
STIPULATED PROTECTIVE ORDER
BETWEEN PLAINTIFF RONALD
PICARD AND WAL-MART STORES,
INC.
IT IS HEREBY STIPULATED, by the PLAINTIFF RONALD PICARD and DEFENDANT WAL-MART STORES, INC. through their attorneys of record that any photographs of company property, floor plans of Store #3350, any schematics of camera locations produced via any method of written or oral discovery, and in any form, by Wal-Mart Stores, Inc. or any of its employees, affiliates, subsidiaries, agents, or attorneys, will be subject to the following limitations on disclosure:
(1) These documents and things shall be limited to the action entitled Ronald Picard v. Wal-Mart Stores, Inc., 2:12-cv-01907-RJC-PAL. Any use of said materials outside of this litigation are strictly prohibited and constitute a breach of this stipulated protective order.
(2) These documents and things will not be disclosed to any person who is not a party to this action unless that person is a retained expert or consultant, in which case all provisions of this Stipulated Protective Order must be shown to that person(s) and that person(s) agree to be bound by the terms of this Stipulated Protective Order.
(3) These documents and things are the property of Wal-Mart Stores, Inc. and contain confidential information of Wal-Mart Stores, Inc. All copies of these documents and things produced, and excerpts therefrom, will be provided to counsel for Defendant Wal-Mart Stores, Inc. at the time the case is resolved by judgment, settlement, dismissal or otherwise.
The above-stipulated limitations on disclosure of Wal-Mart Stores, Inc. confidential information will remain in effect during the pendency of this Action and will remain in effect after the Action is terminated, by judgment, settlement, dismissal or otherwise. Upon resolution of this action, the undersigned counsel agrees that the Wal-Mart Stores, Inc. confidential information will be returned to counsel of record for Defendant Wal-Mart Stores, Inc.
Violation of this Stipulated Protective Order will expose that party and/or its attorney of record to payment of moving party's incurred damages, reasonable attorneys' fees expended in enforcement of this Stipulated Protective Order and sanctions by the Court upon duly-noticed motion. _______________
Keith E. Galliher, Jr., Esq.
Christy Lyn M. Galliher-Gagliano, Esq.
THE GALLIHER LAW FIRM
Attorneys for Plaintiff
_______________
Siria L. Gutiérrez, Esq.
PHILLIPS SPALLAS & ANGSTADT
504 South Ninth Street
Las Vegas, Nevada 89101
Attorneys for Defendant
Wal-Mart Stores, Inc.
IT IS SO ORDERED:
______________________________
UNITED STATES MAGISTRATE JUDGE