Stipulation For Protective Order - United States District Court (Page 5 of 6) in pdf

Stipulation For Protective Order - United States District Court Page 5

non-party then, with respect to the motion, that non-party is entitled to the

same notice and opportunity to be heard as a party. The party or non-

party who designated a document as confidential must show that the

designation satisfies Fed. R. Civ. P. 26(c).

Handling a Confidential Document after Termination of Litigation.

(a)

Within 60 days after the termination of this action (including any appeals),

each party must:

(1)

return or destroy all confidential documents; and

(2)

notify the disclosing or producing party that it has returned or

destroyed all confidential documents within the 60-day period.

(b)

Notwithstanding paragraph 8(a), each attorney may retain a copy of any

confidential document submitted to the court.

Inadvertent Disclosure or Production to a Party of a Protected Document.

(a)

Notice.

(1)

A party or non-party who discovers that it has inadvertently

disclosed or produced a protected document must promptly notify

the receiving party and describe the basis of the claim of privilege

or protection. If the party or non-party provides such notice and

description, the privilege or protection is not waived.

The Parties may draft their stipulation so that it allows retention of other documents as

well — for example, correspondence that quotes or describes a confidential document.

Stipulation For Protective Order - United States District Court Page 5