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Protective Orders

Parties in civil matters frequently request the Court to enter a Protective Order that will govern the use of materials exchanged in discovery in order to preserve the confidentiality of those materials. Parties often jointly propose a draft of such an Order to the Court for signature. These draft Orders tend to be similar overall, but vary—sometimes widely—in terms of specific operational details, often for no apparent reason beyond that the parties started with a protective order they used in a previous case. In an attempt to bring some consistency to Protective Order practice, various other Districts, including for example the Northern District of Ohio, have adopted “form” Protective Orders for use in their Districts. In an effort likewise to promote consistency regarding Protective Order practice in this District, the Southern District of Ohio has prepared draft one-tier (“Confidential”) and two-tier (“Confidential” and “Attorneys Eyes Only”) Protective Orders for use in cases pending here. The draft orders are not “pre-approved,” and individual judges may still require changes to the terms of these orders for use in the cases assigned to them. Moreover, parties may want, or need, specific modifications to address unique aspects of their cases. The Court provides the attached draft Orders to serve as the exemplar for Protective Orders in this District, subject to the above-referenced modifications that may be necessary under the unique circumstances of a given case.

One-Tier Protective Order   (PDF)
One-Tier Protective Order   (Word)

Two-Tier Protective Order   (PDF)
Two-Tier Protective Order   (Word)