provision_id,doc_id,judge_id,rule_number,title,text,source_page,topics,cross_references,judicial_district,county,court_type,doc_type COHEN3-V,188,NY-COMDIV-COHEN-J,V,Confidentiality Orders,"Any proposed order regarding the confidential exchange of information shall be based on the model Stipulation and Order for the Production and Exchange of Confidential Information. If the parties propose to deviate from the Model Order, they shall file: (1) a copy of the parties' proposed confidentiality order; (2) a redline showing proposed deviations; and (3) a letter explaining the reasons for deviations.",,"[""discovery-scheduling""]","[""Commercial Division Rule 11-g""]",1,New York,supreme,part_rules