Standard Protective Order

Protective Orders and Attorneys' Eyes Only (AEO)

Never been a fan of AEO provisions in protective orders unless parties (not counsel) were willing to affirm the information as a trade secret. The categories of "highly confidential" or "commercially sensitive" information are too vague to be subject to any meaningful analysis and the opportunity to over-designate is too great, and the consequences of this can be very real, preventing clients or third-parties from assisting on the case and delaying further resolution of the issues in dispute.

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Idea No. 11