Confidentiality

Discovery cannot be withheld on the basis of confidentiality absent court order. If any document or information produced is deemed confidential by the producing party and if the court has not entered a protective order, the producing party shall mark the document “Confidential – Outside Attorneys’ Eyes Only” and, until such time as the court enters a protective order, disclosure of the confidential document or information must be limited to each party’s outside attorney(s) of record, the employees of such outside attorney(s), and necessary outside document services, unless the parties agree to the contrary. The person(s) to whom disclosure of a confidential document or information is made under this rule must keep it confidential and use it only for the purpose of litigating the case.