Stipulation For Protective Order - United States District Court

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STIPULATION FOR PROTECTIVE ORDER FORM
UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
[NAME OF PARTY],
)
)
Case No. __________
Plaintiff,
)
)
v.
)
STIPULATION FOR
)
PROTECTIVE ORDER
[NAME OF PARTY],
)
)
Defendant.
)
The parties stipulate that the court may enter the following protective order:
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Definitions. As used in this protective order:
(a)
“attorney” means an attorney who has appeared in this action;
(b)
“confidential document” means a document designated as confidential
under this protective order;
(c)
to “destroy” electronically stored information means to delete from all
databases, applications, and file systems so that the information is not
accessible without the use of specialized tools or techniques typically used
by a forensic expert;
(d)
“document” means information disclosed or produced in discovery,
including at a deposition;
(e)
“notice” or “notify” means written notice;
(f)
“party” means a party to this action; and
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