Parties requesting entry of an order to preserve the confidentiality of materials disclosed in discovery must base the proposed order on the Model Confidentiality Order contained in the Local Rules (Form LR26.2), available HERE. The Model Confidentiality Order provides that parties should include or delete language in brackets as necessary to the specific case. Any other proposed changes to this model order must be shown in redlined format that reflects both deletions and additions to the model text. For proposed substantive changes, counsel and parties are encouraged to include comments explaining why the changes are sought.

Counsel shall file a motion for entry of the proposed confidentiality order and attach as an exhibit the redlined proposed order. Counsel shall separately submit a clean copy of the proposed order in Word format to the Court’s proposed order inbox: Proposed_Order_Kness@ilnd.uscourts.gov.

The Court will not enter a proposed confidentiality order suggesting that material a party has designated as “confidential” may, for that reason alone, be filed under seal. Any confidentiality order that contemplates under-seal filing must provide that no documents may be filed under seal absent a motion showing good cause for sealing a portion of the record. A party’s mere designation of information as “confidential” is insufficient to permit filing under seal. A party seeking to file material under seal must instead set forth in its motion the reasons why the record should be sealed. When a party wishes to file a document on the public docket that another party has marked confidential, the parties must meet and confer to determine who is the appropriate party to file any motion to seal.