Local Rule Rule 7037-1: Failure to Make Disclosures or to Cooperate in Discovery; Sanctions.

Rule 7037-1. Failure to Make Disclosures or to Cooperate in Discovery; Sanctions.

(a) Duty to Confer; Certificate of Good Faith.

Prior to service of a motion to compel discovery for whatever reason, all counsel shall be under a duty to confer in good faith to determine to what extent discovery disputes can be resolved before presenting the issue to the bankruptcy judge. No such motion shall be heard by the bankruptcy judge unless counsel for the moving party shall incorporate in the motion a certificate that counsel has conferred in good faith with opposing counsel in an effort to resolve the dispute and has been unable to do so.

(b) Motions Raising Issues Concerning Discovery – Requirements.

Motions raising issues concerning discovery, in accordance with Fed. R. Civ. P. 33, 34, 36 and 37, as adopted by Fed. R. Bankr. P. 7033, 7034, 7036 and 7037, shall quote verbatim each interrogatory, request for production or request for admission to which the motion is addressed, and shall state (i) the specific objection, (ii) the grounds assigned for the objection (if not apparent from the objection itself), and (iii) the reasons assigned as supporting the motion, and shall be written in immediate succession to one another. Such objections and grounds shall be addressed to the specific interrogatory, request for production or request for admission and may not be general in nature.