Bridges v. Kraft Heinz Company

I IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF ILLINOIS
II’SHA BRIDGES,
Plaintiff,
vs.
KRAFT HEINZ COMPANY,
Defendant.
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Case No. 25-cv-02028-DWD
MEMORANDUM & ORDER
DUGAN, District Judge:
Plaintiff Ii’sha Bridges and Defendant Kraft Heinz Foods Company seek to
prevent the unauthorized disclosure of confidential, sensitive, or proprietary information
or documents produced during the course of pre-trial discovery in the above-captioned
action.
Now, therefore, it is hereby stipulated and agreed as follows:
1. 	As used in this Order, “CONFIDENTIAL Material” is defined as information
that the producing party designates in good faith has been previously
maintained in a confidential manner and should be protected from disclosure
and use outside this litigation because its disclosure and use are restricted by
statute or could potentially cause harm to the interests of the disclosing party
or parties. For purposes of this Order, CONFIDENTIAL Material includes the
following categories of information or documents: Financial information
including, but not necessarily limited to, bank records, financial statements,
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and tax returns; Personnel information of individuals who are not party to this
lawsuit; 	Internal 	policies, 	operational 	information, 	complaints 	and
investigations; Proprietary information and trade secrets; Medical records; and
Records, 	documents, 	and 	information 	whose 	disclosure 	is 	restricted 	or
prohibited by regulation, statute, or case law.
2. 	Any party to this litigation may designate any document which it reasonably
believes to be confidential and which it produces during the course of pre-trial
discovery in the above-captioned action as “CONFIDENTIAL,” or a similar
confidential designation subject to the provisions of this Stipulated Protective
Order. It shall be necessary for the designating party to stamp, designate, or
otherwise describe specific documents as CONFIDENTIAL Material in order
for the documents to be afforded the protections set forth in this Stipulated
Protective Order. The parties shall act in good faith in determining whether to
mark a document CONFIDENTIAL.
3. 	All CONFIDENTIAL Material shall be used by the parties hereto, other than
the party or parties by whom production of the particular material is first
made, only for the prosecution or defense of claims made in connection with
the above-captioned action. CONFIDENTIAL Material, or any portion or
recitation thereof, shall not be given or communicated to anyone, except the
following persons:
a. 	The parties, the parties’ counsel, and counsel’s staff, including but not
limited to paralegal and necessary clerical staff;
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b. 	Witnesses, only to the extent the CONFIDENTIAL Material is reasonably
related to their testimony in this litigation;
c. 	The parties’ retained outside experts;
d. 	The Court and its personnel;
e. 	Third-party neutrals retained for alternative dispute resolution of this
litigation;
f. 	Court reporters and/or videographers, and/or third-party document or
other professional services, to the extent necessary relating to a deposition
or potential trial materials;
g. 	Any other person entitled thereto as a matter of legal right or by reason of
compulsion of legal process issued by any court of competent jurisdiction;
h. 	Other persons as designated by the Court or as agreed in writing by the
parties hereto.
4. 	Any persons entitled to receive CONFIDENTIAL Material by virtue of
Paragraph 3 shall first be advised of the existence and content of this Stipulated
Protective Order and shall agree to be bound by the provisions thereof.
5. 	Each person referred to in subparagraphs 3(b), 3(c), 3(g), and 3(h) who has been
shown or given access to CONFIDENTIAL Material, or information derived
therefrom, shall sign an undertaking in the form attached as Exhibit A to this
Order, stating that he or she has read a copy of this Order and agrees to be
bound by its provisions. Signed undertakings shall be retained by counsel for
the party who provides such material or information to such person and shall,
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upon request for good cause, or for any other reason upon order of the Court,
be provided to counsel for the opposing party.
6. 	Except as provided herein, this Stipulated Protective Order shall remain in
effect after this litigation has been concluded by way of settlement, judgment,
or otherwise, including the exhaustion of any and all appeals. No person,
including the parties hereto, having received CONFIDENTIAL Material shall
distribute or communicate that CONFIDENTIAL Material to anyone after the
conclusion of the litigation. Nothing in this Stipulated Protective Order shall
prohibit any party or parties who first produces CONFIDENTIAL Material,
that was rightfully in its possession with any obligation of confidentiality prior
to receiving it, from using or distributing that CONFIDENTIAL Material in
other business matters unrelated to this litigation.
7. 	No party shall be obligated to challenge the propriety or status of any
document as CONFIDENTIAL Material and a failure to make such a challenge
shall not preclude a subsequent challenge to that status by any party. If a party
does 	wish 	to 	challenge 	the 	propriety 	or 	status 	of 	any 	document 	as
CONFIDENTIAL Material, that party shall first seek to resolve the dispute on
an informal basis by meeting and conferring with the opposing party. If the
parties are unable to reach a compromise after good-faith discussion, then they
may raise the dispute with the Court, in accordance with Judge Dugan’s
requirements for discovery disputes.
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8. 	Nothing contained in this Stipulated Protective Order shall bar or otherwise
restrict any attorney from rendering advice to his or her client in this matter
and, in the course thereof, from generally referring to or relying upon his or
her examination of CONFIDENTIAL Material.
9. 	Neither the provisions of this Stipulated Protective Order nor any disclosure
by any party pursuant hereto shall constitute a waiver of any attorney-client,
work product or joint defense/common interest privilege, including the
protections afforded by the Federal Rules of Civil Procedure or by common
law. The terms and provisions of this Stipulated Protective Order shall not be
deemed or interpreted to require the disclosure or production by any party
hereto of any documents or information otherwise subject to a valid claim of
attorney-client, 	work 	product, 	or 	other 	privilege 	or 	protection 	against
disclosure in discovery. In the event any party or person inadvertently or
unintentionally produces or discloses any document or information protected
by the attorney-client privilege, joint defense/common interest privilege, or
any work product doctrine, including but not limited to the protections
afforded by the Federal Rules of Civil Procedure or by common law, the party
or person who receives such document or information shall, upon written
request by the party or person who produced such document or information,
immediately destroy or return it and all copies of it to the party or person who
produced or disclosed such document or information.
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10. Any party may seek a modification or termination of this Stipulated Protective
Order by first attempting to obtain the consent of the other party to the
proposed modification and, absent concurrence, upon application to the Court.
11. This Stipulated Protective Order shall not and does not constitute authority or
authorization for any person not a party hereto to insist upon access to or
inspection of any information or documents to which that person would not,
in the absence of the entry of this Stipulated Protective Order, be otherwise
entitled under law.
12. Use of CONFIDENTIAL Material at trial shall be governed as follows: (a) the
parties may stipulate to the use of materials marked CONFIDENTIAL; or (b)
in the absence of a stipulation, the parties will raise the use of CONFIDENTIAL
Material in their pre-trial motions and the Court will rule on any disputes.
13. Within thirty (30) days of the conclusion of this action, including any appeals,
all parties must destroy all CONFIDENTIAL Material in their possession or in
the possession of their agents, including any copies thereof, that was received
from the other party or any third party. Counsel for the parties, instead of
destroying CONFIDENTIAL Material, may segregate all CONFIDENTIAL
Material to a secure, confidential file, with the understanding that the terms of
this Protective Order shall remain in place as to all such CONFIDENTIAL
Material. Alternatively, counsel may destroy all CONFIDENTIAL Material
received from the other party or any third party. A party or its counsel need
not segregate or destroy CONFIDENTIAL Material the party produced itself,
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if that CONFIDENTIAL Material was rightfully in the party’s possession
without any obligation of confidentiality prior to its production.
14. This Court shall have jurisdiction over the parties hereto with respect to any
dispute 	concerning 	the 	enforcement 	or 	interpretation 	of 	this 	Stipulated
Protective Order and the use of the Stipulated Protective Order.
15. The recipients shall act to minimize the number of persons to whom such
CONFIDENTIAL Material is disclosed. The parties agree to cooperate fully
and in good faith with each other in attempting to resolve any disputes that
may arise as to the terms and effect of this Stipulated Protective Order or any
CONFIDENTIAL designations made hereunder so that recourse of the Court
may be kept to a minimum.
SO ORDERED.
DATED: October 8, 2026
______________________________
DAVID W. DUGAN
United States District Judge
___________________________________
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