Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Saucedo v. Walmart Inc.

United States District Court, M.D. Georgia, Athens Division

December 26, 2019

JUAN GURROLA SAUCEDO, Plaintiff,
v.
WALMART INC., AND CLAIMS MANAGEMENT, INC., Defendants.

          CHANDLER VREELAND, ESQ. ATTORNEY FOR PLAINTIFF

          ROBERT B. HILL ATTORNEY FOR DEFENDANTS

          CONSENT PROTECTIVE ORDER

          HONORABLE CLAY D. LAND JUDGE

         1.

         By agreement of the parties, and for good cause, the Court finds that a protective order should be entered pursuant to Fed.R.Civ.P. 26 (c) for the purpose of protecting documents and information from Plaintiff or Defendants Walmart Inc., Wal-Mart Stores East, LP, Claims Management, Inc. (herein collectively referred to as “Defendants”) or any of their respective affiliates, and of third parties producing records pursuant to subpoena or other discovery proceedings, including but not limited to Marrick Medical Finance, LLC, which the respective parties contend are proprietary and confidential, which are produced by in litigation subject to this protective order, including but not limited to, if applicable, any personnel files or employees or former employees from Defendants; medical records, any training plans for employees; any applicable policies and guidelines relating to business operating methods and procedures; any applicable policies for customer incidents at the store; and store design documents.

         2.

         Any party contesting whether or not a document should be marked “confidential”, will notify the plaintiff or defendant in writing identifying which document he/she contends should not be marked “confidential”. The parties will then have seven (7) business days after receipt of the aforementioned notification to resolve the dispute without Court intervention. If the parties are not able to resolve the dispute within seven (7) business days, the party contesting the description of a document as “confidential” shall, without first filing the document with the Court, submit the document to the Court for an in-camera inspection and final decision as to whether or not the document should remain “confidential”. The parties shall conform to the standing order of this Court (Doc. 5) with regard to the submission of discovery motions regarding any disputes on the designation of documents as confidential.

         3.

         No document, deposition, or tangible thing or other information described in Paragraph 1 may be disclosed to any person, except for the following: counsel of record; persons assisting counsel of record, including outside experts and consultants; directors, officers, and employees of any party; and employees of any party's attorney to whom it is reasonably necessary that the material be disclosed for purposes of this litigation.

         For purposes of any disclosures to persons assisting counsel of record; outside experts or consultants; directors, officers and employees of any party; and employees of any party's attorneys, the party making such a disclosure must: obtain an agreement in writing from the persons assisting counsel, including outside experts or consultants, or officers of employees of either party, reciting that he or she has read a copy of this Protective Order and agrees to be bound by its provisions.

         4.

         If any party proposes to file documents with the Court under seal or to file documents designated as “Confidential” with the Court, the parties shall first notify the opposing party of such intentions and shall then coordinate with the Court an in camera inspection or such other procedure as the Court may direct in order to procure leave of Court for the filing of such documents under seal and shall comply with the provisions of this Section 5 of this Order . The parties shall also coordinate with and comply with any requirements of the Clerk of Court or any Local Rules with respect to the filing of documents under seal. Any documents (including briefs), tangible things or information designated as Confidential that are submitted to the Court in support of or in opposition to a motion or introduced at a hearing or during trial may retain their protected confidential status only by order of the Court in accordance with the procedures this Court's Standing Order (Doc. 5).

         5.

         Each party agrees that before filing any document covered by this protective order with the Clerk of Court any paper (including, without limitation, an affidavit, memorandum, or motion) that discloses directly or indirectly all or part of any document described in paragraph 1 above, such paper shall be labeled "CONFIDENTIAL" and submitted to the Court in camera for consideration and leave to file with the Clerk or otherwise retain such document for the Court record pursuant to the Court record. The parties stipulate and agree that any document covered by paragraph 1 which is reasonably necessary to be filed with the Court in connection with any motion or hearing may be provided to the Court in chambers or at hearing for consideration prior to filing upon obtaining permission from the Court by conference or otherwise to do ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.