Form 5 - Stipulation For Protective Order (Page 4 of 8) in pdf

Form 5 - Stipulation For Protective Order Page 4

transcript.

The deposition of any witness (or any portion of such deposition) that

encompasses Confidential information shall be taken only in the presence of persons who are

qualified to have access to such information.

Any party who inadvertently fails to identify documents as "Confidential" or

"Confidential - Attorneys' Eyes Only" shall have 10 days from the discovery of its oversight to

correct its failure. Such failure shall be corrected by providing written notice of the error and

substituted copies of the inadvertently produced documents. Any party receiving such

inadvertently unmarked documents shall make reasonable efforts to retrieve documents

distributed to persons not entitled to receive documents with the corrected designation.

10. Any party who inadvertently discloses documents that are privileged or

otherwise immune from discovery shall, promptly upon discovery of such inadvertent

disclosure, so advise the receiving party and request that the documents be returned. The

receiving party shall return such inadvertently produced documents, including all copies, within

10 days of receiving such a written request. The party returning such inadvertently produced

documents may thereafter seek re-production of any such documents pursuant to applicable

law.

11. If a party files a document containing Confidential information with the Court, it shall

do so in compliance with the Electronic Case Filing Procedures for the District of Minnesota.

Prior to disclosure at trial or a hearing of materials or information designated "Confidential"

or "Confidential - Attorneys' Eyes Only", the parties may seek further protections against

public disclosure from the Court.

12. Any party may request a change in the designation of any information designated

"Confidential" and/or "Confidential - Attorneys' Eyes Only". Any such document shall be

Form 5 - Stipulation For Protective Order Page 4