EEOC v. Sidley Austin Brown.

Filing 73

MOTION by Plaintiff Equal Employment Opportunity Commission to amend/correct Protective Order (agreed motion) (Attachments: # 1 Exhibit A, proposed Amended Protective Order# 2 Exhibit B, original Protective Order)(Mulaire, Justin)

EEOC v. Sidley Austin Brown.

Doc. 73

Case 1:05-cv-00208

Document 73

Filed 06/15/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff, v. SIDLEY AUSTIN BROWN & WOOD LLP, Defendant. ) ) ) ) ) ) ) ) ) )

Case No. 05 cv 0208 Judge James Zagel Magistrate Judge Ashman

AGREED MOTION TO AMEND PROTECTIVE ORDER

Plaintiff United States Equal Employment Opportunity Commission ("EEOC") respectfully moves this Court to enter the proposed Amended Protective Order, attached as Exhibit A. Defendant Sidley Austin, LLP ("Sidley"), consents to this motion. In support of this motion, the EEOC states the following: 1. On September 2, 2005, the Court entered a protective order ("Protective Order")

in this action, which permits a party to designate certain discovery materials confidential if they contain "Confidential Information," as that term is defined by the Protective Order. See Protective Order, §§ I, III, attached as Exhibit B. 2. The proposed Amended Protective Order includes a new paragraph, designated

§ III.D, which would require a party making a confidentiality designation to contemporaneously identify the basis or bases for that designation. Except for a reference to this Motion in the first sentence of the proposed Amended Protective Order, the remainder of the proposed Amended

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Case 1:05-cv-00208

Document 73

Filed 06/15/2006

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Protective Order is identical to the original Protective Order. In particular, no substantive amendment is proposed. 3. The parties believe the proposed amendment will reduce the frequency of disputes

concerning confidentiality designations and facilitate the resolution of any disputes that do arise. 4. For the reasons stated herein, the EEOC, with Sidley's consent, respectfully

requests that the Court enter the proposed Amended Protective Order.

June 15, 2006

Respectfully Submitted, _s/ Justin Mulaire_______ Laurie Elkin Deborah Hamilton Justin Mulaire Trial Attorneys U.S. Equal Employment Opportunity Commission 500 West Madison St., Room 2800 Chicago, IL 60661 312-353-7722

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