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Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 29 of 32 and not the Court, to set the standards for access. “A blanket protective order is more likely to be subject to modification than a more specific, targeted order because it is more difficult to show a party reasonably relied on a blanket order in producing documents or submitting to a deposition.” Jn re EPDM Antitrust Litig., 255 F.R.D. 308, 319 (D. Conn. 2009). “Stipulated blanket orders are even less resistant to a reasonable request for modification.” Jd. “An examination of Second Circuit case law reveals the following factors are relevant when determining whether a party has reasonably relied on the protective order[:] (1) the scope of the protective order; (2) the language of the order itself; (3) the level of inquiry the court undertook before granting the order; and (4) the nature of reliance on the order.” Jn re September 11 Litig., 262 F.R.D. 274, 277 (S.D.N.Y. 2009) (internal quotation marks omitted). Here, all four factors weigh against a finding of reasonable reliance. First, the Protective Order contains “expansive language granting the parties broad latitude to self-designate materials” as confidential, making it unreasonable for any party to rely on the prospect of indefinite and ironclad confidentiality protections in producing discovery. See EPDM, 255 F.R.D. at 320. Second, the Protective Order allows challenges to confidentiality designations, see Dershowitz Decl., Ex. L § 11, and permits the Court to modify the order “at any time” for good cause, id. J 14. “Given this provision, it is difficult to see how the [parties] can reasonably argue that they produced documents in reliance on the fact that the documents would always be kept secret.” Lugosch, 435 F.3d at 126. Third, “[t]he level of inquiry undertaken before the Order was entered also weighs in favor of modification because the Court ‘so ordered’ the parties’ stipulation without having cause to determine whether all the documents covered actually warranted protection.” Tradewinds Airlines, Inc. v. Soros, No. 08 Civ. 5901, 2016 WL 3951181, at *2 (S.D.N.Y. July 20, 2016). While this practice can be salutary to the extent it preserves judicial resources and 23