Local Rule Rule 37.1: Discovery-Related Motions—Pre-Filing Conference of Counsel

Rule 37.1. Discovery-Related Motions—Pre-Filing Conference of Counsel

(a) Duty to Confer. Prior to filing any motion relating to discovery pursuant to Federal Rules of Civil Procedure 26-37, counsel for the parties shall confer in a good faith effort to eliminate the necessity for the motion or to eliminate as many of the disputes as possible. Such conference shall include oral communication. It shall be the responsibility of counsel for the moving party to arrange for this conference.

(b) Deadline for Completion. Unless otherwise provided by stipulation or by written order of the Court, the conference of counsel shall be completed within 15 calendar days after the moving party serves a written communication requesting such conference. The moving party's letter shall identify each issue and/or discovery request in dispute, state briefly with respect to each the moving party's position, providing any legal authority, and specify the terms of the discovery order to be sought.

(c) Informal Conference with Magistrate Judge. In the event counsel are unable to resolve the areas of dispute, a joint request shall be made for an informal conference with the Magistrate Judge. The joint request should be submitted in email format to the Chambers email address for the Magistrate Judge. It should briefly identify the issues that are in dispute without citation to legal authority. The purpose of the paragraph is to explain the general nature of the dispute rather than to brief the issues as one would do in a motion to compel. If a joint request cannot be made, the party requesting the conference should explain why the request could not be submitted jointly. Counsel are expected to come to the informal conference prepared and with the authority to resolve the disputes.