All counsel requesting entry of an order to preserve the confidentiality of materials disclosed in discovery must base the proposed order on the Model Confidentiality Order
contained in the Local Rules (Form LR 26.2).
The Model Confidentiality Order provides that counsel should include or delete language in brackets as necessary to the specific case. Any other changes to this model protective order proposed by the parties must be shown by redlining that indicates both deletions and additions to the model text.
Counsel are encouraged to include comments with any such proposed changes explaining why the changes are sought.