Agreed Protective Order With Confidentiality Agreement

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, LAW DIVISION

(Plaintiff’s name) )

Plaintiff, )

)

)

v. ) No.__L_____

)

)

(Defendant’s name) )

Defendant )

AGREED PROTECTIVE ORDER

The following Protective Order is hereby entered by the Court in this matter with the agreement of the parties;

1. Confidential documents: A party may designate the following types of documents as confidential: trade secret information, competitively sensitive business planning information, new product research and development information, internal and non-public financial documents reflecting future business plans or future competitive business strategies. Additionally, the parties may designate as confidential information any “Protected Health Information” (PHI), as those terms are used in 45 CFR 160.103 and 160.501, or any other information relating to personal information regarding any individual. The current parties (and their attorneys) and any future parties (and their attorneys) to the above captioned matter are herby authorized to receive, subpoena, and transmit PHI pertaining to any named plaintiff in this action to the extent and subject to the conditions outlined herein. PHI includes, but is not limited to, health information, including demographic information, relating to either, (a) the past, present or future physical condition of an individual, (b) the provision of care to an individual, or (c) the payment for care provided to an individual, which identifies the individual or which reasonably could be expected to identify the individual. All “covered entities” (as defined by 45 CFR 160.103) are hereby authorized to disclose PHI pertaining to any named plaintiff to all attorneys now of record in this matter, or who may become of record in the future of this litigation.

2. Method of designation: Any party may designate individual documents (including writing, recording, and/or documents contained on digital or magnetic media) that fall into the above-described categories (or portions thereof) as confidential by marking the relevant pages with the word “CONFIDENTIAL.” Material so marked is referred to herein as “confidential material.” The production or disclosure of confidential material shall be governed by the terms of the Order unless the confidential designation is withdrawn by the producing party or by order of the Court. Confidential material shall also include all copies of documents designated as confidential.

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