(a) Not later than fourteen (14) days prior to the initial Rule 16 Conference and after
conferring regarding the matter, the parties may, if desired, submit either a
stipulated protective order pursuant to Fed. R. Civ. P. 26(c) or, if agreement
cannot be reached, may each submit a counter proposed protective order for the
Court’s consideration, highlighting for the Court any areas of disagreement. In
the event that the parties do not request the entry of a different Rule 26(c)
confidentiality order at or prior to the Rule 16 scheduling conference, or if
otherwise deemed appropriate, the Court will enter a protective order pursuant to
Fed. R. Civ. P. 26(c) in the form of that provided on the Court’s webpage at
www.nynd.uscourts.gov.
