CONFIDENTIAL MATERIAL IN DISCOVERY

PROTECTIVE ORDERS AND EXCHANGE OF CLAIMED (a) If a party, or parties jointly, seek entry of a protective order to shield information provided in discovery from dissemination, the movant or movants must demonstrate with specificity that (i) (ii) (b) the information qualifies for protection under Rule 26(c) of the Federal Rules of Civil Procedure, and good cause exists for restricting dissemination on the ground that harm would result from its disclosure. Consent Protective Orders may not include a provision for prospective sealing of items filed with the Court, except in accordance with LR 5.4. (c) Nothing in this Local Rule is intended to require prior judicial approval of protective agreements intended to limit access to and use of materials gained in discovery. Instead, the parties may agree to protective agreements that will facilitate the exchange of materials in discovery, including materials as to which there is a claim of confidentiality, without the necessity of Court intervention.

(d) Any response to a motion for entry of a protective order shall be within 14 days after service of the motion. Any reply to a response shall be filed within 7 days after service of the response.