EXHIBIT A 

Case: 1:20-cv-03010 Document #: 100-1 Filed: 02/07/24 Page 1 of 18 PageID #:1372
51617995.1 02/07/2024

Form LR 26.2 

MODEL CONFIDENTIALITY ORDER 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

Plaintiff 

v. 

Defendant 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

Civil No. 

District Judge 

Magistrate Judge 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

OMAR HERNANDEZ and HANNAH ) 

GOLDEN, individually and on behalf ) 

of all others similarly situated, ) No. 20-cv-3010 

 Plaintiffs, ) 

 ) Judge Franklin U. Valderrama 

 v. ) 

ILLINOIS INSTITUTE OF ) Magistrate Judge Keri L. Holleb Hotaling

TECHNOLOGY, ) 

 Defendant. ) 

AGREED CONFIDENTIALITY ORDER 

The parties to this Agreed Confidentiality Order have agreed to the terms of this Order; 

accordingly, it is ORDERED: 

[if not fully agreed] A party to this action has moved that the Court enter a confidentiality 

order. The Court has determined that the terms set forth herein are appropriate to protect the 

respective interests of the parties, the public, and the Court. Accordingly, it is ORDERED: 

Case: 1:20-cv-03010 Document #: 100-1 Filed: 02/07/24 Page 2 of 18 PageID #:1373
2 

1. Scope. All materials produced or adduced in the course of discovery, including 

initial disclosures, responses to discovery requests, documents produced in response to 

subpoenas, deposition testimony and exhibits, and information derived directly therefrom 

(hereinafter collectively “documents”), shall be subject to this Order concerning Confidential 

InformationDiscovery Material as defined below. This Order is subject to the Local Rules of this 

District and the Federal Rules of Civil Procedure on matters of procedure and calculation of time 

periods.

2. Confidential Information.Definitions. 

a) Confidential Discovery Material. As used in this Order, “Confidential Discovery 

Material” means any Confidential Information or Highly Confidential Information that is 

designated as “CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER” or “HIGHLY 

CONFIDENTIAL – ATTORNEY’S EYES ONLY.” 

a)b) Confidential Information. As used in this Order, “Confidential 

Information” means information designated as “CONFIDENTIAL- - SUBJECT TO 

PROTECTIVE ORDER” by the producing party that falls within one or more of the following 

categories: (a1) information prohibited from disclosure by statute; (b or federal rule; (2) 

information that reveals trade secrets; (c3) research, technical, commercial or financial information 

that the party has maintained as confidential; (d4) medical information concerning any individual; 

(e5) personal identity information; (f except as otherwise set forth in subsection (d) below; (6) 

income tax returns (including attached schedules and forms), W-2 forms and 1099 forms; or (g7) 

personnel or employment records of a person who is not a party to the case1. Information or 

documents that are available to the public may not be designated as Confidential Information.

1

 If protection is sought for any other category of information, the additional category shall be described in 

paragraph 2 with the additional language redlined to show the change in the proposed Order.

Case: 1:20-cv-03010 Document #: 100-1 Filed: 02/07/24 Page 3 of 18 PageID #:1374
3 

c) Data Protection Laws. As used in this Order, “Data Protection Laws” means all 

laws and regulations applicable to the processing or disclosure of Personal Data in connection with 

this matter. By way of example only and not limitation, “Data Protection Laws” includes the 

Family Educational Rights and Privacy Act of 1974 (“FERPA”), and the Health Insurance 

Portability and Accountability Act (“HIPAA”) and the regulations promulgated thereunder. 

d) Highly Confidential Information. As used in this Order, “Highly Confidential 

Information” means information designated as “HIGHLY CONFIDENTIAL – ATTORNEY’S 

EYES ONLY” by the producing party that contains the Personal Data of persons not parties to this 

case, including putative class members other than the named Plaintiff. Except with the prior written 

consent of the producing party or by Order of the Court, Highly Confidential Information shall not 

be furnished, shown, or disclosed to any person except those individuals set forth in Paragraphs 

5(b)(1), 5(b)(3), 5(b)(5), 5(b)(6), 5(b)(8), 5(b)(10) and 5(b)(11), below. 

e) Personal Data. As used in this Order, “Personal Data” means highly sensitive 

materials requiring special protection and includes any information that a party believes in good 

faith to be subject to federal, state, or foreign Data Protection Laws that protect and regulate the 

use, storage, and transfer of data of natural persons. By way of example only and not limitation, 

“Personal Data” includes personally identifiable information pursuant to FERPA that is maintained 

in educational records and includes direct identifiers, such as students’ names or identification 

numbers, indirect identifiers such as dates of birth, or other information which can be used to 

distinguish or trace students’ identities either directly or indirectly through linkages with other 

information. 

2.3. Designation. 

. 

Case: 1:20-cv-03010 Document #: 100-1 Filed: 02/07/24 Page 4 of 18 PageID #:1375
4 

a) A party may designate a document as Confidential InformationDiscovery Material

for protection under this Order by placing or affixing the words “CONFIDENTIAL -– SUBJECT 

TO PROTECTIVE ORDER” or “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY” 

on the document and on all copies in a manner that will not interfere with the legibility of the 

document. As used in this Order, “copies” includes electronic images, duplicates, extracts, 

summaries, or descriptions that contain the Confidential Information.Discovery Material. The 

marking “CONFIDENTIAL -– SUBJECT TO PROTECTIVE ORDER” or “HIGHLY 

CONFIDENTIAL – ATTORNEY’S EYES ONLY” shall be applied prior to or at the time of the 

documents are produced or disclosed. Applying the marking “CONFIDENTIAL -– SUBJECT TO 

PROTECTIVE ORDER” or “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY” to a 

document does not mean that the document has any status or protection by statute or otherwise 

except to the extent and for the purposes of this Order. Any copies that are made of any documents 

marked “CONFIDENTIAL -– SUBJECT TO PROTECTIVE ORDER” or “HIGHLY 

CONFIDENTIAL – ATTORNEY’S EYES ONLY” shall also be so marked, except that indices, 

electronic databases, or lists of documents that do not contain substantial portions or images of the 

text of the marked documents and do not otherwise disclose the substance of the Confidential 

InformationDiscovery Material are not required to be marked.

b) The designation of a document as Confidential InformationDiscovery Material is a 

certification by an attorney or a party appearing pro se that the document contains Confidential 

InformationDiscovery Material as defined in this orderOrder.

2

2 An attorney who reviews the documents and designates them as CONFIDENTIAL -– SUBJECT TO 

PROTECTIVE ORDER or HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY must be admitted to the Bar 

of at least one state but need not be admitted to practice in the Northern District of Illinois unless the lawyer is 

appearing generally in the case on behalf of a party. By designating documents confidential pursuant to this Order, 

counsel submits to the jurisdiction and sanctions of this Court on the subject matter of the designation.

Case: 1:20-cv-03010 Document #: 100-1 Filed: 02/07/24 Page 5 of 18 PageID #:1376
5 

3. Depositions.

3

Alternative A. Deposition testimony is protected by this Order only if designated as 

“CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER” on the record at the time the 

testimony is taken. Such designation shall be specific as to the portions that contain Confidential 

Information. Deposition testimony so designated shall be treated as Confidential Information 

protected by this Order until fourteen days after delivery of the transcript by the court reporter to 

any party or the witness. Within fourteen days after delivery of the transcript, a designating party 

may serve a Notice of Designation to all parties of record identifying the specific portions of the 

transcript that are designated Confidential Information, and thereafter those portions identified in 

the Notice of Designation shall be protected under the terms of this Order. The failure to serve a 

timely Notice of Designation waives any designation of deposition testimony as Confidential 

Information that was made on the record of the deposition, unless otherwise ordered by the 

Court. 

c) The producing party may redact Personal Data contained within said materials, 

documents, testimony, or information designated as Highly Confidential Information. 

4. Depositions. 

Unless all parties agree on the record at the time the deposition testimony is taken, all 

deposition testimony taken in this case shall be treated as Confidential InformationDiscovery 

Material until the expiration of the following: No later than the fourteenth day after the transcript 

is delivered to any party or the witness, and in no event later than 60 days after the testimony was 

given,. Within this time period, a party may serve a Notice of Designation to all parties of record 

as to specific portions of the testimony that are designated Confidential Information or Highly 

3

 The parties or movant seeking the order shall select one alternative for handling deposition testimony and 

delete by redlining the alternative provision that is not chosen.

Case: 1:20-cv-03010 Document #: 100-1 Filed: 02/07/24 Page 6 of 18 PageID #:1377
6 

Confidential Information, and thereafter only those portions identified in the Notice of Designation 

shall be protected by the terms of this Order. The failure to serve a timely Notice of Designation 

shall waive any designation of testimony taken in that deposition as Confidential Information or 

Highly Confidential Information, unless otherwise ordered by the Court. 

3.5. Protection of Confidential Material.

. 

a) General Protections. Confidential InformationDiscovery Material shall not be 

used or disclosed by the parties, counsel for the parties, or any other persons identified in 

subparagraph (b) for any purpose whatsoever other than in this litigation, including any appeal 

thereof. [INCLUDE IN PUTATIVE CLASS ACTION CASE: In a putative class action, 

Confidential InformationDiscovery Material may only be disclosed only to the named plaintiff(s)

and not to any other member of the putative class unless and until a class including the putative 

member has been certified.]. Highly Confidential Information may not be disclosed to the named 

plaintiff or any class members.

b) Limited Third-Party Disclosures. The parties and counsel for the parties shall not 

disclose or permit the disclosure of any Confidential InformationDiscovery Material to any third 

person or entity except as set forth in subparagraphs (1)-(910). Subject to these requirements, the 

following categories of persons may be allowed to review Confidential InformationDiscovery 

Material: 

1) Counsel. Counsel for the parties and employees of counsel who have 

responsibility for the action; 

2) Parties. Individual parties, a party’s in-house counsel, and employees 

of a party but only to the extent counsel determines in good faith that 

the employee’s assistance is reasonably necessary to the conduct of the 

litigation in which the information is disclosed; 

Case: 1:20-cv-03010 Document #: 100-1 Filed: 02/07/24 Page 7 of 18 PageID #:1378
7 

3) The Court and its personnel; 

4) Court Reporters and Recorders. Court reporters and recorders 

engaged for depositions; 

5) Contractors. Those persons specifically engaged for the limited 

purpose of making copies of documents or organizing or processing 

documents, including outside vendors hired to process electronically 

stored documents; 

6) Consultants and Experts. Consultants, investigators, or experts 

employed by the parties or counsel for the parties to assist in the 

preparation and trial of this action but only after such persons have 

completed the certification contained in Attachment A, 

Acknowledgment of Understanding and Agreement to Be Bound; 

7) Witnesses at depositions. During their depositions, witnesses in this 

action to whom disclosure is reasonably necessary. Witnesses shall not 

retain a copy of documents containing Confidential 

InformationDiscovery Material, except witnesses may receive a copy of 

all exhibits marked at their depositions in connection with review of the 

transcripts. Pages of transcribed deposition testimony or exhibits to 

depositions that are designated as Confidential InformationDiscovery 

Material pursuant to the process set out in this Order must be separately 

bound by the court reporter and may not be disclosed to anyone except 

as permitted under this Order.; 

8) Author or recipient. The author or recipient of the document (not 

including a person who received the document in the course of 

litigation); and 

9) Others by Consent. Other persons only by written consent of the 

producing party or upon order of the Court and on such conditions as 

may be agreed or ordered.; and 

10) Any Special Discovery Masters or Mediators. Any special discovery 

master appointed by the Court or any mediators with whom the parties 

agree to mediate disputes and the personnel of those special masters or 

mediators. 

11) Any Class Notice Administrator. Any person appointed as a Class 

Notice Administrator for the administration of sending class notices if a 

class is certified. 

c) Control of Documents. Confidential Discovery Material received in electronic 

Case: 1:20-cv-03010 Document #: 100-1 Filed: 02/07/24 Page 8 of 18 PageID #:1379
8 

form shall be maintained in a secure system. If a receiving party discovers an actual breach of 

security of the Confidential Discovery Material subject to this Order, it shall: (1) immediately 

notify the producing party of such breach; (2) investigate the breach; (3) provide reasonable 

information about the breach; and (4) if possible, describe to the producing party the Confidential 

Discovery Material accessed without authorization. Counsel shall maintain the originals of the 

forms signed by persons acknowledging their obligations under this Order, attached hereto as 

Exhibit A, for a period of three years after the termination of the case.Counsel for the parties shall 

make reasonable efforts to prevent unauthorized or inadvertent disclosure of Confidential 

Information. Counsel shall maintain the originals of the forms signed by persons acknowledging 

their obligations under this Order for a period of three years after the termination of the case.

4. Inadvertent Failure to Designate. An inadvertent failure to designate a 

document as Confidential InformationDiscovery Material does not, standing alone, waive the 

right to so designate the document; provided, however, that a failure to serve a timely Notice of 

Designation of deposition testimony as required by this Order, even if inadvertent, waives any 

protection for deposition testimony. If a party designates a document as Confidential 

InformationDiscovery Material after it was initially produced, the receiving party, on notification 

of the designation, must make a reasonable effort to assure that the document is treated in 

accordance with the provisions of this Order. No party shall be found to have violated this Order 

for failing to maintain the confidentiality of material during a time when that material has not 

been designated Confidential InformationDiscovery Material, even where the failure to so 

designate was inadvertent and where the material is subsequently designated Confidential 

Information.Discovery Material. 

7. Inadvertent Disclosure of Privileged Information. 

Case: 1:20-cv-03010 Document #: 100-1 Filed: 02/07/24 Page 9 of 18 PageID #:1380
9 

a) The parties agree that they do not intend to disclose information subject to a legally 

recognized claim of privilege or other protection (including, without limitation, the attorney-client 

privilege, the work-product doctrine, or other applicable privilege) (“Non-Discoverable 

Information”). If, nevertheless, the producing party inadvertently discloses Non-Discoverable 

Information to another party, such disclosure shall not constitute or be deemed a waiver or 

forfeiture of the privilege or protection from discovery in this case or in any other federal or state 

proceeding by that party. Consistent with Federal Rule of Evidence 502(d) and the ESI Order 

entered in this case, this Order shall be interpreted to provide the maximum protection allowed by 

Federal Rule of Evidence 502(d). 

b) If a producing party discovers that it inadvertently disclosed any Non-Discoverable 

Information, document, or thing claimed to be protected by privilege or work-product immunity, 

it shall promptly (no later than fourteen (14) business days after discovery) notify the receiving 

party in writing. Such inadvertent disclosure of such information, document, or thing shall not 

constitute a waiver by the producing party of any claims of privilege or work-product protection. 

c) A party that discovers that it may have received Non-Discoverable Information or 

otherwise protected document(s) shall promptly (no later than fourteen (14) business days after 

discovery) notify the producing party in writing and shall promptly (within five (5) business days 

after notification) return or destroy the document without distributing, disseminating, or 

reproducing the document, and shall retrieve or destroy the document to the extent such document 

has already been distributed, disseminated, or reproduced. 

d) Within seven (7) days of the notification that such Non-Discoverable Information 

has been returned, destroyed, or deleted, the producing party shall produce a privilege log with 

respect to the inadvertently produced Non-Discoverable Information. Within seven (7) days after 

Case: 1:20-cv-03010 Document #: 100-1 Filed: 02/07/24 Page 10 of 18 PageID #:1381
10 

receiving the disclosing party’s privilege log, a receiving party may notify the disclosing party in 

writing of any objection to a claim of privilege or work-product protection with respect to the 

inadvertently produced Non-Discoverable Information. Within fourteen (14) days of the receipt of 

such notification, the disclosing party and the receiving party shall meet and confer in an effort to 

resolve any disagreement concerning the disclosing party’s privilege or work-product claim. The 

parties may stipulate to extend the time periods set forth in this paragraph. 

e) If, for any reason, the parties do not resolve their disagreement after conducting a 

meet and confer, the party disputing the privileged nature of the document or information may 

seek relief from the Court. A party who disagrees with the privilege designation must nevertheless 

abide by that designation until the matter is resolved by agreement of the parties or by order of the 

Court. 

f) The producing party bears the burden of establishing the privileged or protected 

nature of any inadvertently produced Non-Discoverable Information. 

5. Filing of Confidential InformationDiscovery Material. This Order does not, by 

itself, authorize the filing of any document under seal. Any party wishing to file a document 

designated as Confidential InformationDiscovery Material in connection with a motion, brief or 

other submission to the Court must comply with LR 26.2. 

6. No Greater Protection of Specific Documents. Except on privilege grounds not 

addressed by this Order, no party may withhold information from discovery on the ground that it 

requires protection greater than that afforded by this Order unless the party moves for an order 

providing such special protection.

7. Challenges by a Party to Designation as Confidential Information.Discovery 

Material. The designation of any material or document as Confidential InformationDiscovery 

Case: 1:20-cv-03010 Document #: 100-1 Filed: 02/07/24 Page 11 of 18 PageID #:1382
11 

Material is subject to challenge by any party. The following procedure shall apply to any such 

challenge. 

a) Meet and Confer. A party challenging the designation of Confidential 

InformationDiscovery Material must do so in good faith and must begin the process by conferring 

directly with counsel for the designating party. In conferring, the challenging party must explain 

the basis for its belief that the confidentiality designation was not proper and must give the 

designating party an opportunity to review the designated material, to reconsider the designation, 

and, if no change in designation is offered, to explain the basis for the designation. The designating 

party must respond to the challenge within five (5) business days.

b) Judicial Intervention. A party that elects to challenge a confidentiality 

designation may file and serve a motion that identifies the challenged material and sets forth in 

detail the basis for the challenge. Each such motion must be accompanied by a competent 

declaration that affirms that the movant has complied with the meet and confer requirements of 

this procedure. The burden of persuasion in any such challenge proceeding shall be on the 

designating party. Until the Court rules on the challenge, all parties shall continue to treat the 

materials as Confidential InformationDiscovery Material under the terms of this Order. 

8. Action by the Court. Applications to the Court for an order relating to materials 

or documents designated Confidential InformationDiscovery Material shall be by motion. 

Nothing in this Order or any action or agreement of a party under this Order limits the Court’s 

power to make orders concerning the disclosure of documents produced in discovery or at trial. 

9. Use of Confidential Documents or InformationDiscovery Material at Trial. 

Nothing in this Order shall be construed to affect the use of any document, material, or 

information at any trial or hearing. A party that intends to present or that anticipates that another 

Case: 1:20-cv-03010 Document #: 100-1 Filed: 02/07/24 Page 12 of 18 PageID #:1383
12 

party may present Confidential informationDiscovery Material at a hearing or trial shall bring 

that issue to the Court’s and parties’ attention by motion or in a pretrial memorandum without 

disclosing the Confidential Information.Discovery Material. The Court may thereafter make such 

orders as are necessary to govern the use of such documents or information at trial. 

10. Confidential InformationDiscovery Material Subpoenaed or Ordered 

Produced in Other Litigation. 

a) If a receiving party is served with a subpoena or an order issued in other litigation 

that would compel disclosure of any material or document designated in this action as Confidential 

InformationDiscovery Material, the receiving party must so notify the designating party, in 

writing, immediately and in no event more than three court days after receiving the subpoena or 

order. Such notification must include a copy of the subpoena or court order. 

b) The receiving party also must immediately inform in writing the party who caused 

the subpoena or order to issue in the other litigation that some or all of the material covered by the 

subpoena or order is the subject of this Order. In addition, the receiving party must deliver a copy 

of this Order promptly to the party in the other action that caused the subpoena to issue.

c) The purpose of imposing these duties is to alert the interested persons to the 

existence of this Order and to afford the designating party in this case an opportunity to try to 

protect its Confidential InformationDiscovery Material and/or to take the necessary actions, if any, 

to comply with any Data Protection Laws, in the court from which the subpoena or order was 

issued. The designating party shall bear the burden and the expense of seeking protection in that 

court of its Confidential InformationDiscovery Material, and nothing in these provisions should 

be construed as authorizing or encouraging a receiving party in this action to disobey a lawful 

directive from another court. The obligations set forth in this paragraph remain in effect while the 

Case: 1:20-cv-03010 Document #: 100-1 Filed: 02/07/24 Page 13 of 18 PageID #:1384
13 

party has in its possession, custody, or control Confidential InformationDiscovery Material by the 

other party to this case. 

11. Challenges by Members of the Public to Sealing Orders. A party or interested 

member of the public has a right to challenge the sealing of particular documents that have been 

filed under seal, and the party asserting confidentiality will have the burden of demonstrating the 

propriety of filing under seal.

12.15. Obligations on Conclusion of Litigation. 

. 

a) Order Continues in Force. Unless otherwise agreed or ordered, this Order shall 

remain in force after dismissal or entry of final judgment not subject to further appeal.

b) Obligations at Conclusion of Litigation. Within sixty-three days after dismissal 

or entry of final judgment not subject to further appeal, all Confidential InformationDiscovery 

Material and documents marked “CONFIDENTIAL -– SUBJECT TO PROTECTIVE ORDER” 

or “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY” under this Order, including 

copies as defined in ¶ 3(a), shall be returned to the producing party unless: (1) the document has 

been offered into evidence or filed without restriction as to disclosure; (2) the parties agree to 

destruction to the extent practicable or in lieu of return;4

 or (3) as to documents bearing the 

notations, summations, or other mental impressions of the receiving party, that party elects to 

destroy the documents and certifies to the producing party that it has done so.

c) Retention of Work Product and one set of Filed Documents. Notwithstanding 

4 The parties may choose to agree that the receiving party shall destroy documents containing Confidential 

InformationDiscovery Material and certify the fact of destruction, and that the receiving party shall not be required to 

locate, isolate, and return e-mails (including attachments to e-mails) that may include Confidential 

InformationDiscovery Material, or Confidential InformationDiscovery Material contained in deposition transcripts or 

drafts or final expert reports. 

Case: 1:20-cv-03010 Document #: 100-1 Filed: 02/07/24 Page 14 of 18 PageID #:1385
14 

the above requirements to return or destroy documents, counsel may retain (1) attorney work 

product, including an index that refers or relates to designated Confidential InformationDiscovery 

Material so long as that work product does not duplicate verbatim substantial portions of 

Confidential InformationDiscovery Material, and (2) one complete set of all documents filed with 

the Court including those filed under seal. Any retained Confidential InformationDiscovery 

Material shall continue to be protected under this Order. An attorney may use his or her work 

product in subsequent litigation, provided that its use does not disclose or use Confidential 

Information.Discovery Material. 

d) Deletion of Documents filed under Seal from Electronic Case Filing (ECF) 

System. Filings under seal shall be deleted from the ECF system only upon order of the Court. 

12. Order Subject to Modification. This Order shall be subject to modification by 

the Court on its own initiative or on motion of a party or any other person with standing 

concerning the subject matter. 

13. No Prior Judicial Determination. This Order is entered based on the 

representations and agreements of the parties and for the purpose of facilitating discovery. 

Nothing herein shall be construed or presented as a judicial determination that any document or 

material designated Confidential InformationDiscovery Material by counsel or the parties is 

entitled to protection under Rule 26(c) of the Federal Rules of Civil Procedure or otherwise until 

such time as the Court may rule on a specific document or issue. 

14. Persons Bound. This Order shall take effect when entered and shall be binding 

upon all counsel of record and their law firms, the parties, and persons made subject to this Order 

by its terms. 

Case: 1:20-cv-03010 Document #: 100-1 Filed: 02/07/24 Page 15 of 18 PageID #:1386
15 

 WE SO MOVE and agree to abide by the terms of this Order 

PLAINTIFFS OMAR HERNANDEZ AND 

HANNAH GOLDEN 

By: /s/ Daniel J. Kurowski 

Daniel J. Kurowski 

Whitney K. Siehl 

Hagens Berman Sobol 

Shapiro LLP 

455 N. Cityfront Plaza Dr., Suite 2410 

Chicago, IL 60611 

Telephone: (708) 628-4949 

dank@hbsslaw.com 

whitneys@hbsslaw.com 

Steve W. Berman 

Hagens Berman Sobol 

Shapiro LLP

1301 Second Avenue, Suite 2000 

Seattle, WA 98101 

Telephone (206) 623-7292 

steve@hbsslaw.com 

Eric M. Poulin (Pro Hac Vice) 

Roy T. Willey, IV (Pro Hac Vice) 

Paul J. Doolittle (Pro Hac Vice) 

Blake G. Abbott (Pro Hac Vice) 

POULIN | WILLEY | ANASTOPOULO, 

LLC 

32 Ann Street 

Charleston, SC 29403 

(P): (803) 222-2222 

(F): (843) 494-5536 

eric@poulinwilley.com 

roy@poulinwilley.com 

Paul.doolittle@poulinwilley.com 

Blake.abbott@poulinwilley.com 

ILLINOIS INSTITUTE OF TECHNOLOGY 

By: /s/ William T. “Toby” Eveland 

One of its attorneys 

William T. “Toby” Eveland 

(toby.eveland@saul.com) 

Nancy DePodesta 

(nancy.depodesta@saul.com) 

James A. Morsch 

(jim.morsch@saul.com) 

Elizabeth A. Thompson 

(elizabeth.thompson@saul.com) 

Andrew E. Bollinger 

(andrew.bollinger@saul.com) 

Saul Ewing LLP 

161 North Clark Street, Suite 4200, Chicago, 

Illinois 60601 

(312) 876-7100 

Case: 1:20-cv-03010 Document #: 100-1 Filed: 02/07/24 Page 16 of 18 PageID #:1387
A-16

40569861.1 09/28/202251617995.1

ATTACHMENT A 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

OMAR HERNANDEZ and HANNAH ) 

GOLDEN, individually and on behalf ) 

of all others similarly situated, ) No. 20-cv-3010 

 Plaintiffs, ) 

 ) Judge Franklin U. Valderrama 

 v. ) 

ILLINOIS INSTITUTE OF ) 

TECHNOLOGY, ) 

 Defendant. ) 

ACKNOWLEDGMENT

AND

AGREEMENT TO BE BOUND

 The undersigned hereby acknowledges that he/she has read the Agreed Confidentiality 

Order dated ____________________________ in the 

above-captioned action and attached hereto, understands the terms thereof, and agrees to be bound 

by its terms. 

The undersigned submits to the jurisdiction of the United States District Court for the 

Northern District of Illinois in matters relating to the Agreed Confidentiality Order and 

understands that the terms of the Agreed Confidentiality Order obligate him/her to use materials 

designated as Confidential InformationDiscovery Material in accordance with the Order solely for 

the purposes of the above-captioned action, and not to disclose any such Confidential 

InformationDiscovery Material to any other person, firm or concern. 

 The undersigned acknowledges that violation of the Agreed Confidentiality Order may 

result in penalties for contempt of court. 

Case: 1:20-cv-03010 Document #: 100-1 Filed: 02/07/24 Page 17 of 18 PageID #:1388
A-17

40569861.1 09/28/202251617995.1

Name: 

 

Job Title: 

 

Employer: 

 

Business Address: 

 

 

Date: 

Name: ______________________________________ 

Job Title: ______________________________________ 

Employer: ______________________________________ 

Business Address: ___________________________ 

 ___________________________ 

 ___________________________ 

Date: _________________ ___________________________ 

 Signature 

Adopted 06/29/12

Case: 1:20-cv-03010 Document #: 100-1 Filed: 02/07/24 Page 18 of 18 PageID #:1389