Parties who request entry of an order to preserve the confidentiality of material disclosed in discovery shall do so by motion. Counsel must
attach the proposed order to the motion as an exhibit and base the proposed order on the Model Confidentiality Order contained in the
should add the bracketed language to or delete it from the Model Confidentiality Order as appropriate for a specific case. Any other changes to the Model Confidentiality Order that the parties propose must be shown by redlining that
indicates both the deletions and additions to the model text. Counsel should also include brief comments
with any proposed changes explaining why the changes are sought.
Counsel should also submit the proposed protective order to the court's proposed order e-mail box at Proposed_Order_Alonso@ilnd.uscourts.gov
in non-redlined Word format. Please do not submit PDF files to the court's proposed order e-mail box. The subject line of the e-mail must contain the case name and number, the docket number of the motion, and the title of the proposed order.