Filed: Mar. 07, 2016
Latest Update: Mar. 07, 2016
Summary: LIMITED STIPULATION AND ORDER REGARDING AGREED PROTECTIVE ORDER CAM FERENBACH , Magistrate Judge . COMES NOW, Defendant, THE VONS COMPANIES, INC., by and through its undersigned attorneys, LEW BRANDON, JR., ESQ., JUSTIN W. SMERBER, ESQ. of MORAN BRANDON BENDAVID MORAN, Plaintiff, RENISHA NIEVES, by and through her attorney, JOSHUA DOWLING, ESQ. of COGBURN LAW OFFICES and request an Order as follows: Defendant has produced the following items, which the parties agree shall be designated as
Summary: LIMITED STIPULATION AND ORDER REGARDING AGREED PROTECTIVE ORDER CAM FERENBACH , Magistrate Judge . COMES NOW, Defendant, THE VONS COMPANIES, INC., by and through its undersigned attorneys, LEW BRANDON, JR., ESQ., JUSTIN W. SMERBER, ESQ. of MORAN BRANDON BENDAVID MORAN, Plaintiff, RENISHA NIEVES, by and through her attorney, JOSHUA DOWLING, ESQ. of COGBURN LAW OFFICES and request an Order as follows: Defendant has produced the following items, which the parties agree shall be designated as ..
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LIMITED STIPULATION AND ORDER REGARDING AGREED PROTECTIVE ORDER
CAM FERENBACH, Magistrate Judge.
COMES NOW, Defendant, THE VONS COMPANIES, INC., by and through its undersigned attorneys, LEW BRANDON, JR., ESQ., JUSTIN W. SMERBER, ESQ. of MORAN BRANDON BENDAVID MORAN, Plaintiff, RENISHA NIEVES, by and through her attorney, JOSHUA DOWLING, ESQ. of COGBURN LAW OFFICES and request an Order as follows:
Defendant has produced the following items, which the parties agree shall be designated as confidential, proprietary and subject to protection in this action until the Court has ruled on a Motion for Protective Order regarding such items. Accordingly, it is agreed Defendant will file a Motion for Protective Order regarding the above-mentioned items by no later than March 28, 2016. In the event Defendant fails to do so, the following items will not be deemed to be confidential, proprietary or subject to the protection in this action.
1. Employee file of Adam Garbar;
2. Employee file of Angela Baca;
3. Employee file of Larry Garbar;
4. Master Agreement for Floor Care — Janitorial Services between Safeway, Inc./The Vons Company, Inc. and Come Land Maintenance Service Company dated April 20, 2014;
5. Termination of Services Letter from The Vons Company, Inc. to Come Land Maintenance Co, Inc. dated March 23, 2015;
6. Courtesy Clerk Bottom of Basket Policy and Guidelines;
7. Annual Sweep Program Policy and Guidelines;
8. Safeway/Vons Companies Courtesy Clerk Cleaning Training Materials;
9. Safeway/Vons Companies Culture of Safety Training Materials Presentation;
10. Meat/Seafood Departments Sanitation Reference Guide;
11. Welcome to Safeway/Vons Companies Training Guide Presentation;
12. Floor Care Trainer's Guide;
13. Floor Care Training Evaluation Guide; and
14. Vons Loss Report for falls 2009-2016.
Pending the Court's ruling on Defendant's Motion for Protective Order to be filed by no later than March 28, 2016, the foregoing confidential documents and information contained therein shall be used solely for the prosecution or defense of this litigation. Such confidential documents and information may be disclosed only to the following persons: (a) parties to this litigation; (b) counsel for the parties and persons regularly employed in the offices of counsel for the parties; (c) outside experts or professional advisors retained by a party to assist in the prosecution or defense in the case and persons regularly employed in the offices of such outside experts and professional advisors; (d) court personnel, deponents and court reporters/videographers; provided, however, that prior to such disclosure to the persons describing clause (a) and (c) above, counsel shall furnish a copy of this Protective Order to such person and obtain the written agreement of such person to be bound by the terms of this Protective Order. The requirement of obtaining such a written agreement may be satisfied by obtaining the signature of any such person at the foot of a copy of this Order.
Nothing contained in this Protective Order shall preclude Defendant from using its own confidential documents or information in any manner they see fit, or from reviewing such confidential documents or information to whomever they choose, without the prior consent of any other party or of this Court.
MORAN BRANDON BENDAVID MORAN COGBURN LAW OFFICES
________________________________ __________________________________
LEW BRANDON, JR., ESQ. JAMIE S. COGBURN, ESQ.
Nevada Bar No. 5880 Nevada Bar No. 8409
JUSTIN W. SMERBER, ESQ. JOSHUA DOWLING, ESQ.
Nevada Bar No. 10761 Nevada Bar No. 12956
KRIS D. KLINGENSMITH, ESQ. 2879 St. Rose Parkway, Suite 200
Nevada Bar No. 13904 Henderson, Nevada 89052
630 S. Fourth Street Attorneys for Plaintiff,
Las Vegas, Nevada 89101 RENISHA NIEVES
Attorneys for Defendant,
THE VONS COMPANIES, INC.
IT IS SO ORDERED.
