IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

PAJOJE DEVELOPMENT, LLC, 

 Plaintiff, 

 v. 

JOHN DOE(S), 

 Defendants. 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

)

Case Number 1:20-CV-04948 

AGREED CONFIDENTIALITY 

ORDER 

IN RESPECT TO JOHN DOE 

DISCOVERY INFORMATION

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

accordingly, it is ORDERED: 

1. Definitions. 

(a) “Action” means the above-captioned action. 

(b) “Discoverable Information” means all materials produced by Cboe Global 

Markets, Inc., Cboe Futures Exchange, LLC, and Cboe Exchange, Inc. (“Cboe”) in connection 

with or response to Plaintiff’s Motion for early discovery (Dkt. 5). 

(c) “Document” is synonymous in meaning and equal in scope to the usage of this term 

in Federal Rule of Civil Procedure 34(a)(l)(A). 

(d) “ESI” shall have the same meaning and scope as it has in Federal Rule of Civil 

Procedure 34(a)(1)(A). 

(e) “Party” means a Party to the Action only that has executed this Stipulation. 

(f) “Producing Party” means Cboe. 

Case: 1:20-cv-04948 Document #: 18 Filed: 12/14/20 Page 1 of 16 PageID #:100
(g) “Receiving Party” means Counsel for Pajoje Development, LLC (“Pajoje” and/or 

“Plaintiff”) in this Action. References to “Plaintiff” herein is limited to Counsel for this Plaintiff. 

2. Scope. Discoverable Information shall be subject to this Order concerning 

Confidential Information 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.

3. Confidential Information. As used in this Order, “Confidential Information” 

means all Discoverable Information. For the sake of clarity, this definition, however, does not 

extend to any information that the Receiving Party has previously purchased from Cboe or may 

purchase in the future, and the Parties agree that this Protective Order will not govern information 

other than that produced by Cboe in connection with or in response to Plaintiff’s Motion for Early 

Discovery (Dkt. 5). 

4. Designation. 

(a) In order to designate all Discoverable Information as Confidential Information for 

protection under this Order, Cboe shall place or affix the words “CBOE CONFIDENTIAL – 

SUBJECT TO PROTECTIVE ORDER” on the media used to produce or disclose the Discoverable 

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

summaries, or descriptions that contain the Confidential Information. The marking “CBOE 

CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER” shall be applied prior to or at the time 

the documents are produced or disclosed. Applying the marking “CBOE CONFIDENTIAL – 

SUBJECT TO PROTECTIVE ORDER” 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 “CBOE CONFIDENTIAL – SUBJECT TO 

PROTECTIVE ORDER” 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 marked documents and do 

not otherwise disclose the substance of the Confidential Information are not required to be marked. 

Whenever the Receiving Party to whom electronically stored Discoverable Information so designated 

is produced reduces such information to hard copy form, to the extent such pages have not previously 

Case: 1:20-cv-04948 Document #: 18 Filed: 12/14/20 Page 2 of 16 PageID #:101
been marked by the Producing Party, such Receiving Party shall mark the hard copy by affixing the 

designation “Cboe Confidential,” “Cboe Internal,” or “Cboe Restricted” to each page of such 

document. 

(b) The designation of a document as Confidential Information is a certification by an 

attorney that the document contains Confidential Information as defined in this Order.

5. Protection of Confidential Material. 

(a) General Protections. Confidential Information shall not be used or disclosed by 

Counsel or any other persons identified in subparagraph (b) to this paragraph for any purpose 

whatsoever other than in the litigation of the Action, including any appeal thereof. 

(b) Limited Third-Party Disclosures. Cboe and Plaintiff shall not disclose or permit 

the disclosure of any Confidential Information to any third person or entity except as set forth in 

subparagraphs (1)-(8) to this paragraph. Subject to these requirements, the following categories of 

persons may be allowed to review Confidential Information:

(1) Plaintiff’s Counsel. Counsel for the Plaintiff and employees of Counsel who have 

responsibility for the Action;

(2) Defendants’ Counsel. Counsel for Defendants to the Action and employees of 

Counsel who have responsibility for the Action, but only after such Counsel have 

executed a stipulation in substantially the same form as this Stipulation.

(3) The Court and its personnel. And any Court Reporters, videographers and their 

staff engaged for depositions, and mediators (and staff) appointed by the Parties to 

assist in alternative dispute resolution;

(4) Contractors. Those persons or entities who provide litigation support services 

(e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, 

and organizing, storing, or retrieving in any form or medium) and their employees 

and subcontractors;

(5) Consultants, Investigators, and Experts. Consultants, investigators, or experts 

employed by Counsel to assist in the preparation and trial of this Action but only 

after such individual persons have completed the certification contained in 

Attachment A, Acknowledgment of Understanding and Agreement to Be Bound, 

have agreed to the data security provisions of Attachment B, and provided further 

that any part of a report created by such consultant, investigator or expert 

incorporating Confidential Information shall be designated appropriately by the 

Case: 1:20-cv-04948 Document #: 18 Filed: 12/14/20 Page 3 of 16 PageID #:102
Party responsible for its creation; and provided further that consultants, 

investigators or experts shall not use Confidential Information for any purpose that 

does not relate to this Action (including but not limited to other litigation and other 

work in their respective field); 

(6) Insurers’ counsel. The counsel representing the insurer or indemnitor of Cboe or 

Plaintiff, including the insurer’s or indemnitor’s legal team, provided such counsel 

signs Attachment A prior to any disclosure;

(7) Witnesses in this Action. Witnesses to whom disclosure is reasonably necessary 

during depositions or testimony at trial or any hearing, provided that Counsel for 

the Plaintiff intending to disclose the information has a good-faith basis for 

believing such Confidential Information is relevant to events, transactions, 

discussions, communications, or data about which the witness is expected to testify 

or about which the witness may have knowledge, provided that Plaintiff instructs 

the witness and their counsel that the material is subject to this Protective Order, 

provide them with a copy of the same, and have them execute Attachment A. 

Witnesses shall not retain a copy of documents containing Confidential 

Information, except witnesses may review a copy of all exhibits marked at their 

depositions in connection with review of the transcripts; and

(8) Others by Consent. Other persons only by written consent of Cboe or upon order 

of the Court and on such conditions as may be agreed or ordered, in addition to 

those persons having signed Attachment A.

(c) Summaries. Counsel for Plaintiff may provide summaries or characterizations of 

the Confidential Information to individuals employed by the Plaintiff, who has 

responsibility to make decisions regarding the prosecution or settlement of the Action. 

Nothing in this Order is intended to bar or otherwise prevent Plaintiff’s counsel from 

rendering advice to its respective client with respect to this Action and, in the course of 

rendering such advice, from relying upon its examination or knowledge of Confidential 

Information.

(d) Control of Documents. Counsel for the Parties shall make reasonable efforts to 

prevent unauthorized or inadvertent disclosure of Confidential Information. Counsel and 

any third-parties to whom disclosure is permitted by this Order, with the exception of the 

Court and its personnel, shall also implement the specific controls set forth in Attachment 

B to this Order. To the extent that Confidential Information is ESI or is converted to ESI, 

Case: 1:20-cv-04948 Document #: 18 Filed: 12/14/20 Page 4 of 16 PageID #:103
it shall be stored and transmitted only in fully encrypted form as set forth in the ESI 

Protocol. 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. In the event that there is an unauthorized disclosure of Confidential 

Information, Cboe will be provided with a list of those who have executed Attachment B.

6. The recipient of any Confidential Information shall maintain such information in a 

secure and safe area and shall exercise a standard of due and proper care with respect to the storage, 

custody, use, and/or dissemination sufficient under all applicable laws, including by establishing, 

maintaining, and enforcing written policies and procedures consistent with NIST Security and Privacy 

Controls for Federal Information Systems and Organizations (Special Publication 800-53 Rev. 4) 

(“NIST 800-53”) or substantially similar security standards promulgated by another widely 

recognized organization, to safeguard against unauthorized or inadvertent disclosure of such material 

to persons or entities not authorized under this Order, and also agree to the requirements for data 

security set forth in Attachment B. In addition, the recipient of Confidential Information shall produce 

to Cboe a current SOC 2 Type 2 report demonstrating reasonable design and operating effectiveness 

of recipient’s information security-related controls. Confidential Information shall not be copied, 

reproduced, extracted, or abstracted, except to the extent that such copying, reproduction, extraction, 

or abstraction is reasonably necessary for the conduct of this Action. All such copies, reproductions, 

extractions, and abstractions shall be subject to the terms of this Order. The recipient of any original 

media shall notify Cboe once the data has been copied, reproduced, extracted, or abstracted, and 

shall return the original data file to Cboe. Cboe will maintain the produced data for the duration of 

the litigation. 

Case: 1:20-cv-04948 Document #: 18 Filed: 12/14/20 Page 5 of 16 PageID #:104
7. Unauthorized Disclosure of Confidential Information. If Plaintiff or any thirdparty to whom disclosure is permitted by this Order learns that, by inadvertence or otherwise, they 

have disclosed Confidential Information to any person or in any circumstance not authorized under 

this Order, they must within one business day of learning of the disclosure take the following 

actions: (a) notify Cboe in writing of the unauthorized disclosures; (b) use their best efforts to 

retrieve all unauthorized copies of the Confidential Information; (c) inform the person or persons 

to whom unauthorized disclosures were made of all the terms of this Order; and (d) request such 

person or persons destroy the Confidential Information.

8. Filing of Confidential Information. Any Party wishing to file Confidential 

Information must seek to file such information in redacted form or under seal in accordance with the 

rules of this Court unless Cboe provides its written agreement that the Confidential Information may 

be publicly filed. This Order does not, by itself, authorize the filing of any document under seal. Any 

Party wishing to file a document designated as Confidential Information in connection with a motion, 

brief or other submission to the Court must comply with LR 26.2.

9. Inadvertent Production of Privileged or Otherwise Protected Material. If Cboe 

inadvertently or mistakenly produces privileged material, such production shall in no way 

prejudice or otherwise constitute a waiver of, or estoppels as to any claim of privilege, workproduct immunity, protection pursuant to the joint defense or common interest doctrine, or any 

other applicable privilege for the inadvertently produced document or any other document 

covering the same or a similar subject matter under applicable law including Federal Rule of 

Evidence 502. When Cboe gives notice to Plaintiff that certain inadvertently produced material is 

subject to a claim of privilege or other protection, the obligations of the Plaintiff are those set forth 

in Federal Rule of Civil Procedure 26(b)(5)(B). Pursuant to Federal Rule of Evidence 502(d) and 

Case: 1:20-cv-04948 Document #: 18 Filed: 12/14/20 Page 6 of 16 PageID #:105
(e), insofar as Cboe and Plaintiff reach an agreement on the effect of disclosure of a communication 

or information covered by the attorney-client privilege or work product protection, the Parties may 

incorporate their agreement in a stipulated protective order submitted to the court.

10. Challenges by a Party to Designation as Confidential Information. The 

designation of any material or document as Confidential Information is subject to challenge by 

Plaintiff, and such challenge may be made at any time. The following procedure shall apply to any 

such challenge.

(a) Meet and Confer. Plaintiff must meet and confer directly with Counsel for Cboe 

before challenging the designation of Confidential Information. In conferring, Plaintiff must 

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

Cboe 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. Cboe must respond to the 

challenge within five (5) business days of the conferral.

(b) Judicial Intervention. If Plaintiff elects to challenge a confidentiality designation, 

it 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 

Information under the terms of this Order.

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

or documents designated Confidential Information shall be by motion. Nothing in this Order or 

Case: 1:20-cv-04948 Document #: 18 Filed: 12/14/20 Page 7 of 16 PageID #:106
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.

12. Use of Confidential Documents or Information 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 party may present Confidential 

Information 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. The Court may 

thereafter make such orders as are necessary to govern the use of such documents or information 

at trial.

13. Confidential Information Subpoenaed or Ordered Produced in Other 

Litigation. 

(a) If Plaintiff 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 

Information, it must so notify Cboe, in writing, within three (3) court days after receiving the 

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

(b) Plaintiff also must 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 and must deliver a copy of this Order promptly to the Party in the other Action 

that caused the subpoena to issue. The purpose of imposing these duties is to alert the interested 

persons to the existence of this Order and to afford Cboe an opportunity to try to protect their 

Confidential Information in the court from which the subpoena or order issued. Cboe shall bear the 

burden and the expense of seeking protection in that court of their Confidential Information, and 

nothing in these provisions should be construed as authorizing or encouraging a Plaintiff in this 

Case: 1:20-cv-04948 Document #: 18 Filed: 12/14/20 Page 8 of 16 PageID #:107
Action to disobey a lawful directive from another court. The obligations set forth in this paragraph 

remain in effect while Plaintiff has Confidential Information in its possession, custody, or control. 

14. 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.

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 (63) days after 

dismissal or entry of final judgment not subject to further appeal, all Confidential Information and 

documents marked “CBOE CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER” under this 

Order that have not already been returned pursuant to paragraph 6 above shall be returned to Cboe 

or destroyed to the extent practicable (including, directing the Plaintiff’s discovery vendor(s) to take 

data offline or to take other steps to prevent access to the documents) in a manner that is consistent 

with the highest industry standards (e.g., the DoD 5220.22-M data sanitization method, in 

accordance with the Department of Defense National Industrial Security Program Operating 

Manual), unless the document has been offered into evidence or filed without restriction as to 

disclosure. With respect to Confidential Information stored in electronic form, the Receiving Party 

shall apply physical or logical techniques that render data recovery infeasible using state of the art 

laboratory techniques in conformity with the NIST SP 800-88 R1 Purge standard. 

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

above requirements to return or destroy documents, Plaintiff’s Counsel may retain (1) attorney work 

Case: 1:20-cv-04948 Document #: 18 Filed: 12/14/20 Page 9 of 16 PageID #:108
product, including an index that refers or relates to designated Confidential Information so long as 

that work product does not duplicate verbatim portions of Confidential Information, (2) email 

correspondence related to its representation, so long as those correspondences do not duplicate 

verbatim portions of Confidential Information; and (3) one complete set of all: (i) documents filed 

with the Court including those filed under seal; (ii) all transcripts of depositions, including exhibits; 

and (iii) all final expert witness reports and supporting materials disclosed pursuant to Rule 26 of the 

Federal Rules of Civil Procedure. Counsel are not required to return or destroy Confidential 

Information that is stored on backup storage media made in accordance with regular data backup 

procedures for disaster recovery purposes; or (2) is located in the email archive system or archived 

electronic files of departed employees so long as the archived emails or files do not duplicate 

verbatim portions of the Confidential Information. Any retained Confidential Information 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.

(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.

16. 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. 

17. 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 Information by counsel or the parties is entitled to protection under Rule 

Case: 1:20-cv-04948 Document #: 18 Filed: 12/14/20 Page 10 of 16 PageID #:109
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.

18. 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.

19. Miscellaneous.

(a) Right to Object. By stipulating to the entry of this Order, no Party waives any right

it otherwise would have to object to disclosing or producing any information or item on any ground 

not addressed in this Order. Similarly, no Party waives any right to object on any ground to use in 

evidence of any of the material covered by this Order.

(b) Additional Parties. In the event that a new Party is added, substituted, or otherwise

brought into this Action, this Order will be binding on and inure to the benefit of the new Party 

once that new Party has executed the Acknowledgement and Agreement to be Bound, subject to 

the right of the new Party to seek relief from or modification of this Order.

So Ordered. 

Dated: 

U.S. District Judge 

Manish S. Shah 

December 14, 2021

Case: 1:20-cv-04948 Document #: 18 Filed: 12/14/20 Page 11 of 16 PageID #:110
WE SO MOVE 

and agree to abide by the 

terms of this Order 

/s/ Jason W. Burge

Jason W. Burge (pro hac vice) 

SBN (LA) 30420 

Lara K. Richards (pro hac vice) 

FISHMAN HAYGOOD L.L.P. 

201 St. Charles Avenue, 46th Floor 

New Orleans, Louisiana 70170-4600 

(504) 586-5252; (504) 586-5250 fax 

jburge@fishmanhaygood.com 

lrichards@fishmanhaygood.com 

Alexander Loftus, Esq. 

David Eisenberg, Esq. 

Loftus & Eisenberg, Ltd. 

161 N. Clark St., Suite 1600 

Chicago, Illinois 60601 

T: 312.899.6625 

C: 312.772.5396 

alex@loftusandeisenberg.com 

david@loftusandeisenberg.com 

Counsel to Pajoje Development, LLC 

WE SO MOVE 

and agree to abide by the 

terms of this Order 

s/ Gregory M. Boyle 

Gregory M. Boyle 

JENNER & BLOCK LLP 

353 N. Clark Street 

Chicago, IL 60654-3456 

(312) 923-2651 

gboyle@jenner.com 

Attorney for Cboe Exchange, Inc. 

Case: 1:20-cv-04948 Document #: 18 Filed: 12/14/20 Page 12 of 16 PageID #:111
1577125v.1

ATTACHMENT A 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

PAJOJE DEVELOPMENT, LLC, 

 Plaintiff, 

 v. 

JOHN DOE(S), 

 Defendants. 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

)

Case Number 1:20-CV-04948 

AGREED CONFIDENTIALITY 

ORDER 

IN RESPECT TO JOHN DOE 

DISCOVERY INFORMATION

ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND 

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

________ in the above-captioned action and attached hereto, as well as the requirements for data 

security set forth in Attachment B, understands the terms thereof, and agrees to be bound by all of 

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

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

terms of the Confidentiality Order obligate him/her to use materials designated as Confidential 

Information in accordance with the Order and in accordance with the requirements for data security 

set forth in Attachment B, solely for the purposes of the above- captioned action, and not to 

disclose any such Confidential Information to any other person, firm or concern. 

The undersigned acknowledges that violation of the Confidentiality Order or the 

requirements for data security set forth in Attachment B may result in penalties for contempt of 

court. 

Case: 1:20-cv-04948 Document #: 18 Filed: 12/14/20 Page 13 of 16 PageID #:112
1577125v.1

Name: _________________________________________________________________________ 

Job Title: _______________________________________________________________________ 

Employer: ______________________________________________________________________ 

Business Address: _______________________________________________________________ 

Date: _____________ Signature:___________________________

Case: 1:20-cv-04948 Document #: 18 Filed: 12/14/20 Page 14 of 16 PageID #:113
1577125v.1

ATTACHMENT B 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

PAJOJE DEVELOPMENT, LLC, 

 Plaintiff, 

 v. 

JOHN DOE(S), 

 Defendants. 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

)

Case Number 1:20-CV-04948 

AGREED CONFIDENTIALITY 

ORDER 

IN RESPECT TO JOHN DOE 

DISCOVERY INFORMATION

AGREEMENT TO BE BOUND BY CERTAIN PROTOCOLS GOVERNING ESI 

The undersigned hereby acknowledge that in handling any Discoverable Information, 

they will maintain and enforce written policies and procedures consistent with NIST Security 

and Privacy Controls for Federal Information Systems and Organizations (Special Publication 

800-53 Rev. 4) or substantially similar security standards promulgated by another widely 

recognized organization. In addition, any receiving party who will host Discoverable 

Information must provide to Cboe a current SOC 2 Type 2 report demonstrating reasonable 

design and operating effectiveness of recipient’s information security related controls. The 

receiving party shall also satisfy the following Compliance Checklist demonstrating adequate 

security control: 

1) Security: Information and systems are protected against unauthorized access, unauthorized 

disclosure, and damage to the system that could compromise the information or systems and 

effect the entity’s ability to meet its security obligations. Security includes the protection of: 

a) Discoverable Information 

Case: 1:20-cv-04948 Document #: 18 Filed: 12/14/20 Page 15 of 16 PageID #:114
1577125v.1

b) Systems that are used to analyze, host, store, extract, or otherwise contain Discoverable 

Information; 

2) Availability: The system includes controls to support accessibility for operation, monitoring, 

and maintenance; 

3) Processing Integrity: The system’s ability to process data is complete, valid, accurate, timely, 

and able to meet and comply with the objectives set forth above; 

4) Confidentiality: Information that is designated as Confidential Information, as set out in the 

protective order above, will be protected and designated as such by the system used; 

5) Privacy: To the extent that personal information is collected, used, and revealed, the host will 

limit the use of such data to the terms set forth above; and 

6) Purge: At the conclusion of the use of all data, the system is capable of applying physical or 

logical techniques that render recovery of the data infeasible using state of the art laboratory 

techniques in conformity with NIST SP 800-88 R1 Purge standard. 

7) The undersigned acknowledges that violation of the Confidentiality Order or the 

requirements for data security set forth in Attachment B may result in penalties for contempt 

of court. 

Name: _________________________________________________________________________ 

Job Title: _______________________________________________________________________ 

Employer: ______________________________________________________________________ 

Business Address: _______________________________________________________________ 

Date: _____________ Signature:___________________________ 

Case: 1:20-cv-04948 Document #: 18 Filed: 12/14/20 Page 16 of 16 PageID #:115