Protective Orders Seeking Confidential Treatment of Materials or Information Produced, or to be Produced, During Discovery

A party seeking a protective order to allow for the confidential treatment of materials or information to be produced during discovery shall file a motion which must include:

    1.  A factual statement of the basis for a protective order;
    2.  A statement of all parties’ agreement or objection to the motion;
    3.  An attached proposed protective order using the template provided below customized (using redlining or track changes) to the case as well as a copy of the proposed Order submitted pursuant to this Court’s ECF Manual, p. 18;
    4.  A statement of any changes to the template (as shown using redlining or track changes) with the reasons for the requested changes or a statement indicating that no changes were made to the template; and
    5.  A statement that the motion is in compliance with these instructions.