Confidentiality

(a) Discovery cannot be withheld or delayed on the basis of confidentiality absent Court order. Pending entry of a confidentiality order, discovery and disclosures designated confidential by a party shall be produced to the adverse party for outside counsels’ Attorneys’ Eyes Only, solely for purposes of the pending case and shall not be disclosed to the client or any other person. -2- (b) Not later than fourteen (14) days after the initial CMC the parties shall submit either a stipulated confidentiality order pursuant to Fed. R. Civ. P. 26(c) or, if agreement cannot be reached, shall each submit a counter proposed confidentiality order for the Court’s consideration, highlighting for the Court any areas of disagreement.