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

_assets/_documents/_forms/_online/26.2%20FORM.pdf .

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.