Proposed Protective (Confidentiality) Orders
When preparing a proposed protective/confidentiality order, the parties should refer to Local Rules 5.7, 5.8 and 26.2. Furthermore, the court has adopted a Model Confidentiality Order to facilitate the exchange of discovery materials that are entitled to protection under Fed. R. Civ. P. 26. It can be found at
The model order is for the convenience of the parties and the court and not intended to create a presumption in favor of the provisions in the model order and/or against any alternative language that the parties may propose. To simplify the court’s review, however, to the extent that the provisions in a proposed protective order differ from those set forth in the model order, the party or parties seeking the entry of the proposed order should indicate, by means of a redlined document, the differences between the proposed order and the model order.
Parties seeking entry of a proposed protective (confidentiality) order also must file a motion with the Court seeking that relief unless otherwise directed by the Court. The motion should attach as exhibits both a redlined proposed order and a clean proposed order so that if the proposed changes are acceptable and appropriate, the court can enter the clean proposed order. Those exhibits should also be emailed to Proposed_Order_Lee@ilnd.uscourts.gov in Microsoft Word format so that the Court may make any necessary edits. The subject line of the e-mail must include the case number and name. The Court will determine the appropriateness of any proposed order on a case by case basis.