STIPULATED PROTECTIVE ORDER BETWEEN PLAINTIFF BERNADETTE CARRIZZO AND DEFENDANT WAL-MART STORES, INC.

NANCY J. KOPPE, Magistrate Judge.

The Parties to this action, Plaintiff BERNADETTE CARRIZZO (hereinafter "Plaintiff") and Defendant WAL-MART STORES, INC. (hereinafter "Defendant") (collectively, the "Parties"), by and through their respective counsel of record, hereby stipulate and request that the Court enter a Stipulated Protective Order as follows:

1. This Protective Order shall be entered pursuant to the Federal Rules of Civil Procedure and applicable Local Rules for the United States District Court for the District of Nevada.

2. This Protective Order shall govern all materials agreed upon as "Confidential" by the Parties. Disclosed materials agreed to be "Confidential" in nature shall be designated in writing as "Confidential," and such designation may appear on the face of each document or in a separate writing. The Parties will use best efforts to limit the number of documents designated as "Confidential." "Confidential Information" in this case shall include, but not be limited to, Plaintiff's medical records, Defendant's policies and procedures, Defendant's training materials, and any maps and/or schematics of the subject Defendant store.

3. "Confidential Information" shall be held in confidence by each Party or by his or her representatives, attorneys, and/or agents for use solely for the purposes of this action and not for any business purpose. Documents designated as "Confidential" may not be disclosed to persons or parties whose relationship to the dispute between the Parties is not reasonably related to the prosecution or defense of claims litigated.

4. Each counsel shall be responsible for providing notice of this Protective Order and the terms herein to persons to whom they disclose "Confidential Information," as defined by the terms of this Protective Order.

5.

See order issued concurrently herewith.

6. The termination of this action shall not relieve the Parties and persons obligated hereunder from their responsibilities to maintain the confidentiality of Information designated "Confidential" pursuant to this Protective Order.

7. After the final adjudication or resolution of this Lawsuit ("final adjudication" will include the resolution of any appeals), a Party may make a written demand to the other Party for the return of "Confidential" materials, including all copies and reproductions thereof. The Party receiving the written demand shall have thirty (30) days from receipt of the written demand to comply with same.

8. Nothing in this Protective Order shall be deemed to preclude any Party from seeking and obtaining, on an appropriate showing, a modification of this Protective Order.

9. To the extent any aspect of this Protective Order may conflict with a subsequent Court Order or Local Rule, that aspect of this Protective Order is superseded with that Court Order or Local Rule.

IT IS SO ORDERED.