STIPULATED PROTECTIVE ORDER BETWEEN PLAINTIFF ROSALIND MARTINEZ AND DEFENDANTS SAM'S WEST, INC. AND WAL-MART STORES, INC.

CAM FERENBACH, Magistrate Judge.

STIPULATED PROTECTIVE ORDER

The parties to this action, Defendants Wal-Mart Stores, Inc. and Sam's West, Inc. ("Defendants"), and Plaintiff, Rosalind Martinez, by their respective counsel, hereby stipulate and request that the Court enter a stipulated protective order pursuant as follows:

1. The Protective Order shall be entered pursuant to the Federal Rules of Civil Procedure and applicable local rules for the United States District Court, District of Nevada

2. The Protective Order shall govern all materials identified as "Confidential" by the parties. Disclosed materials claimed to be confidential in nature shall be produced by placing the following legend on the face of each document and each page so designated "CONFIDENTIAL" or otherwise expressly identified as confidential. The parties will use best efforts to limit the number of documents designated as "Confidential." Confidential Information in this case shall include the following: all Defendants' policies and procedures and training materials (Bates Nos. WM2015-015637-0001 through WM2015-015637-0148), information regarding prior claims in the subject Sam's Club store (Bates No. WM2015-015637-0193), and maps/schematics of the subject Sam's Club store (Bates No. WM2015-015637-0163).

3. Confidential Information shall be held in confidence by each party or his or her representatives, attorneys, agents, and so forth, 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 the Protective Order and the terms therein to persons to whom they disclose "Confidential Information," as defined by the terms of the Protective Order.

5. The parties will file under seal any confidential information included in any papers, motions, or pleadings to avoid the public disclosure of said information. Pursuant to LRIA 10-5 and Kamakana v. City and County of Honolulu, 447 F.3d 1172 (9th Cir. 2006)

6. The termination of this action shall not relieve the parties and persons obligated hereunder from their responsibility to maintain the confidentiality of information designated confidential pursuant to this 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 the Protective Order shall be deemed to preclude any party from seeking and obtaining, on an appropriate showing, a modification of this Order.

The terms of the above stipulation for a protective order by and between Defendants, Wal-Mart Stores, Inc. and Sam's West, Inc. and Plaintiff, Rosalind Martinez, by their respective counsel, shall hereby be the ORDER of this Court.