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 trial may enter the following protective order: 1 Definitions. As used in this protective (a) an attorney who has appeared in this action; “attorney” (b) document” means a document designated as confidential “confidential under this protective order; (c) to electronically stored information means to delete from all “destroy” 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) means information disclosed or produced in discovery, “document” including at a deposition; (e) or means written notice; “notice” “notify” (f) means a party to this action; and “party”
STIPULATION FOR PROTECTIVE ORDER FORM UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA [NAME OF PARTY], Plaintiff, v. [NAME OF PARTY], Defendant. ) ) ) ) ) ) ) ) ) Case No. __________ STIPULATION FOR PROTECTIVE ORDER The parties stipulate that the may enter the following protective order: 1 Definitions. As used in this protective (a) “attorney” 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 trial
Stipulation-for-Protective-Order-Form.docx