Proposed confidentiality stipulations and protective orders must contain a provision
acknowledging that the designation of “confidential” is not sufficient to warrant sealing, and that
requests for sealing shall be governed by Local Rule 5.3, notwithstanding the entry of a
protective order. In cases involving voluminous productions, parties are encouraged to include in
proposed protective orders a “clawback” provision as provided under Federal Rule of Evidence
502(d).
