Form 5 - Stipulation For Protective Order
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8FORM 5. STIPULATION FOR PROTECTIVE ORDER
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MINNESOTA
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Case No. ___________
[NAME OF PARTY],
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Plaintiff,
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STIPULATION FOR
v.
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PROTECTIVE ORDER
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[NAME OF PARTY],
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Defendant.
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Upon stipulation of the parties for an order pursuant to Fed. R. Civ. P. 26(c) that trade
secret or other confidential information be disclosed only in designated ways:
1.
As used in the Protective Order, these terms have the following meanings:
"Attorneys" means counsel of record;
"Confidential" documents are documents designated pursuant to paragraph 2;
"Confidential - Attorneys' Eyes Only" documents are the subset of Confidential
documents designated pursuant to paragraph 5;
"Documents" are all materials within the scope of Fed. R. Civ. P. 34;
"Written Assurance" means an executed document in the form attached as Exhibit A.
2.
By identifying a document "Confidential", a party may designate any document,
including interrogatory responses, other discovery responses, or transcripts, that it in good
faith contends to constitute or contain trade secret or other confidential information.
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