M.D.N.C. LR 5.5

[__] Conference: The parties have discussed the issues of confidentiality raised in this

case and the potential need for filing documents under seal. That discussion included the

nature of any confidential documents that may be involved in the case, the possibility of

using stipulations to avoid the need to file certain documents, and the possibility of

agreed-upon redactions of immaterial confidential information in filings to avoid the need

for filing documents under seal.

[__] Non-Parties: Because a non-party has produced documents pursuant to a

protective order or is otherwise claiming confidentiality over documents filed or expected

to be filed in this case, the conference included ___________________________

(identify non-party).

[__] Default: The parties certify that few, if any, documents will be filed under seal.

The parties agree to use the default procedures of LR 5.4(c). In addition, if the party

filing the motion to seal is not the party claiming confidentiality, the filing party must

meet and confer with the party claiming confidentiality as soon as practicable, but at least

two (2) days before filing the documents, to discuss narrowing the claim of

confidentiality. The motion to seal must certify that the required conference has

occurred, and the party claiming confidentiality must file supporting materials required

by LR 5.4(c)(3) within 14 days of the motion to seal.

[__] Alternative Proposal for Cases with Many Confidential Documents.

In order to address claims of confidentiality and reduce the need to file briefs and

exhibits under seal, the parties propose the alternative procedure set out in the attached

proposal, either jointly or as competing alternatives, for consideration by the Court.

[] Other relevant information: _______________________________