1 HALL & EVANS, LLC KURT R. BONDS, ESQ. 2 Nevada Bar No. 6228 3 TANYA M. FRASER, ESQ. Nevada Bar No. 13872 4 1160 North Town Center Drive Suite 330 5 Las Vegas, Nevada 89144 (702) 998-1022 6 [email protected] 7 Attorneys for Defendant Sam’s West, Inc.

UNITED STATES DISTRICT COURT 8

DISTRICT OF NEVADA 9

MARIA SILVERIO, individually, CASE NO.: 2:23-cv-02044-CDS-BNW 10

11 Plaintiff, v. 12 SAM’S WEST, INC., a Foreign Corporation; STIPULATED PROTECTIVE 13 DOE MANAGERS I through X; DOE ORDER MAINTENANCE and/or INSPECTION 14 EMPLOYEES or AGENTS I through X; 15 DOES I through XX; ROE PROPERTY MANAGEMENT ENTITIES I through X; 16 ROE MAINTENANCE and/or INSPECTION ENTITIES I through X; and ROE 17 CORPORATIONS and/or ENTITIES I through XX, inclusive, 18

19 Defendants. 20 STIPULATED PROTECTIVE ORDER 21 The parties to this action, Plaintiff MARIA SILVERIO and Defendant SAM’S WEST, INC., 22 by and through their respective attorneys of record, hereby stipulate and request that the Court enter 23 a stipulated protective order pursuant as follows: 24 1. The Protective Order shall be entered pursuant to the Federal Rules of Civil 25 Procedure. 26 2. The Protective Order shall govern all materials deemed to be “Confidential 27 Information.” Such Confidential Information shall include the following: 1 human resources or business information; financial records of the parties; 2 compensation of Defendant’s current or former personnel; policies, 3 procedures and/or training materials of Defendant and/or Defendant’s 4 organizational structure; 5 b. Any documents from the personnel, medical or workers’ compensation file of 6 any current or former employee or contractor; 7 c. Any documents relating to the medical and/or health information of Plaintiff 8 or any of Defendant’s current or former employees or contractors; 9 d. Any portions of depositions (audio or video) where Confidential Information 10 is disclosed or used as exhibits. 11 3. In the case of documents and the information contained therein, designation of 12 Confidential Information produced shall be made by (1) identifying said documents as confidential 13 in Defendant’s FRCP 26(a) disclosures and any supplements made thereto; (2) placing the following 14 legend on the face of the document and each page so designated “CONFIDENTIAL;” or (3) 15 otherwise expressly identified as confidential via written correspondence. Both parties will use their 16 best efforts to limit the number of documents designated Confidential. 17 4. Confidential Information shall be held in confidence by each qualified recipient to 18 whom it is disclosed, shall be used only for purposes of this action, shall not be used for any business 19 purpose, and shall not be disclosed to any person who is not a qualified recipient. All produced 20 Confidential Information shall be carefully maintained so as to preclude access by persons who are 21 not qualified recipients. 22 5. Qualified recipients shall include only the following: 23 a. In-house counsel and law firms for each party and the secretarial, clerical and 24 paralegal staff of each; 25 b. Deposition notaries and staff; 26 c. Persons other than legal counsel who have been retained or specially 27 employed by a party as an expert witness for purposes of this lawsuit or to 1 d. Deponents during the course of their depositions or potential witnesses of this 2 case; and 3 e. The parties to this litigation, their officers and professional employees. 4 6. Each counsel shall be responsible for providing notice of the Protective Order and 5 the terms therein to persons to whom they disclose “Confidential Information,” as defined by the 6 terms of the Protective Order. 7 Persons to whom confidential information is shown shall be informed of the terms of this 8 Order and advised that its breach may be punished or sanctioned as contempt of the Court. Such 9 deponents may be shown Confidential materials during their deposition but shall not be permitted to 10 keep copies of said Confidential materials nor any portion of the deposition transcript reflecting the 11 Confidential Information. 12 If either party objects to the claims that information should be deemed Confidential, that 13 party’s counsel shall inform opposing counsel in writing within thirty (30) days of receipt of the 14 Confidential materials that the information should not be so deemed, and the parties shall attempt 15 first to dispose of such disputes in good faith and on an informal basis. If the parties are unable to 16 resolve their dispute, they may present a motion to the Court objecting to such status. The 17 information shall continue to have Confidential status during the pendency of any such motion. The 18 party asserting the label of “Confidential” shall bear the burden of showing the same within said 19 motion to show why said document is entitled to such protection. 20 7. No copies of Confidential Information shall be made except by or on behalf of 21 attorneys of record, in-house counsel or the parties in this action. Any person making copies of such 22 information shall maintain all copies within their possession or the possession of those entitled to 23 access to such information under the Protective Order. 24 8. Any party that inadvertently discloses or produces in this action a document or 25 information that it considers privileged or otherwise protected from discovery, in whole or in part, 26 shall not be deemed to have waived any applicable privilege or protection by reason of such 27 disclosure or production if, within 14 days of discovering that such document or information has 1 identifying the document or information in question, the asserted privileges or protection, and the 2 grounds there for, with a request that all copies of the document or information be returned or 3 destroyed. The receiving party shall return or destroy the inadvertently disclosed documents, upon 4 receipt of appropriately marked replacement documents. 5 9. The termination of this action shall not relieve the parties and persons obligated 6 hereunder from their responsibility to maintain the confidentiality of information designated 7 confidential pursuant to this Order. 8 10. Within thirty (30) days of the final adjudication or resolution of this Lawsuit, the 9 party receiving Confidential Information shall destroy said information, including all copies and 10 reproductions thereof. 11 11. Nothing in this Order shall be construed as an admission to the relevance, 12 authenticity, foundation or admissibility of any document, material, transcript or other information. 13 12. Nothing in the Protective Order shall be deemed to preclude any party from seeking 14 and obtaining, on an appropriate showing, a modification of this Order. 15 IT IS SO STIPULATED. 16 DATED this 1st day of May, 2024. DATED this 1st day of May, 2024. PATERNOSTER LAW GROUP HALL & EVANS, LLC 17 /s/ Glenn Paternoster________________ /s/ _Kurt R. Bonds______________ 18 GLENN A. PATERNOSTER, ESQ. KURT R. BONDS, ESQ. 19 Nevada Bar No. 5452 Nevada Bar #6228 300 South 4th Street, Suite 1600 1160 North Town Center Drive 20 Las Vegas, Nevada 89101 Suite 330 Telephone: (702) 654-1111 Las Vegas, Nevada 89144 21 Facsimile: (702) 522-1522 (702) 998-1022 [email protected] [email protected] 22 Attorneys for Plaintiff Attorneys for Defendant Sam’s West, Inc. 23 24

25 26 27 1 Silverio v. Sam’s West, Inc. Case No. 2:23-cv-02044-CDS-BNW 2 Stipulated Protective Order 3 ORDER 4 5 The terms of the above stipulation for a protective order by and between Plaintiff Maria 6 Silverio and Defendant Sam’s West, Inc., by their respective counsel, shall hereby be the ORDER 7 of this Court. 8 9 _M__a_y_ _2_, _2_0_2_4_____ _____________________________________ 10 DATE UNITED STATES MAGISTRATE JUDGE 11 12 SUBMITTED this 1st day of May, 2024. 13 HALL & EVANS, LLC 14 /s/Kurt R. Bonds_________________________ 15 KURT R. BONDS, ESQ. Nevada Bar No. 6228 16 1160 North Town Center Dr., Ste 330 Las Vegas, Nevada 89144 17 (702)998-1022 [email protected] 18 Attorneys for Defendant Sam’s West, Inc. 19 20 IT IS FURTHER ORDERED that should the parties seek to file documents under seal, the 21 parties' motions to seal must comply with LR IA 10-5 and Kamakana v. City & Cnty. of Honolulu, 22

(9th Cir. 2006). 23 24 25 26 27