D. Mass. L.R. 116.6

(a) Declination. If in the judgment of a party it would be detrimental to the interests of justice

to make any of the disclosures required by these rules, such disclosures may be declined,

before or at the time that disclosure is due, and the opposing party advised in writing, with

a copy filed with the clerk, of the specific matters on which disclosure is declined and the

reasons for declining. If the opposing party seeks to challenge the declination, that party

shall file a motion to compel that states the reasons why disclosure is sought. Upon the

filing of such motion, except to the extent otherwise provided by law, the burden shall be

on the party declining disclosure to demonstrate, by affidavit and supporting memorandum

citing legal authority, why such disclosure should not be made. The declining party may

file its submissions in support of declination under seal pursuant to L.R. 7.2 for the court's

in camera consideration. Unless otherwise ordered by the court, a redacted version of each

such submission shall be served on the moving party, which may reply.

(b) Ex Parte Motions for Protective Orders. This rule does not preclude any party from

moving under L.R. 7.2 and ex parte (that is, without serving the opposing party) for leave

to file an ex parte motion for a protective order with respect to any discovery matter. Nor

does this rule limit the court's power to accept or reject an ex parte motion or to decide such

a motion in any manner it deems appropriate.