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. ) 

JOINT MOTION FOR ENTRY OF PROPOSED AGREED 

CONFIDENTIALITY ORDER AND STIPULATED PROTOCOL 

ON THE DISCOVERY OF ELECTRONICALLY STORED INFORMATION 

 Plaintiffs, Omar Hernandez and Hannah Golden, and Defendant, Illinois Institute of 

Technology (individually “party,” and collectively the “parties”), by their undersigned attorneys, 

jointly move this Court for the entry of the proposed Agreed Confidentiality Order and Stipulated 

Protocol on the Discovery of Electronically Stored Information, and in support thereof, state as 

follows: 

1. The parties have agreed that discovery in this matter may include production of 

confidential documents that warrant protection by a confidentiality order. The parties have 

negotiated the terms of such an order and submit to the court a proposed confidentiality order 

attached as Exhibit A. 

2. The proposed order attached as Exhibit A is the Model Confidentiality Order for 

the United States District Court for the Northern District of Illinois as well as redlines showing the 

parties’ updates. A clean copy of the proposed confidentiality order is attached as Exhibit B. 

3. The parties also believe that discovery in this matter will involve the production of 

electronically stored information and have negotiated a proposed stipulation on the discovery of 

such materials attached as Exhibit C. The parties likewise request that this Court enter the attached 

Case: 1:20-cv-03010 Document #: 100 Filed: 02/07/24 Page 1 of 3 PageID #:1369
2 

stipulation, which will govern the parties’ production of all electronically stored information in 

this case. 

WHEREFORE, the parties respectfully request that this Court enter the agreed 

confidentiality order attached hereto as Exhibit A and the Stipulated Protocol on the Discovery of 

Electronically Stored Information attached as Exhibit B. 

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 

TelephoneL (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 Filed: 02/07/24 Page 2 of 3 PageID #:1370
3 

CERTIFICATE OF SERVICE 

 The undersigned, an attorney, certifies that on February 7, 2024, the undersigned 

electronically filed the foregoing Joint Motion for Entry of Proposed Agreed Confidentiality 

Order and Stipulated Protocol on the Discovery of Electronically Stored Information with 

the Clerk of Court by using the CM/ECF system, which sent notification of such filing to all parties 

of record. 

 

 /s/ Andrew E. Bollinger 

Case: 1:20-cv-03010 Document #: 100 Filed: 02/07/24 Page 3 of 3 PageID #:1371