Local Rule LR 37.1: MOTIONS TO COMPEL A DISCLOSURE OR DISCOVERY

LR 37.1 MOTIONS TO COMPEL A DISCLOSURE OR DISCOVERY

(A) Form. A motion to compel a disclosure under LR 26.1 or to compel a response to discovery conducted pursuant to the Federal Rules of Civil Procedure shall:

(1) Include the certification of counsel with regard to the duty to confer required by Fed. R. Civ. P. 37(a)(2)(A)(B);

(2) Quote verbatim each disclosure, interrogatory, deposition question, request for designation of deponent, or request for inspection to which objection is taken;

(3) State the specific objection;

(4) State the grounds assigned for the objection (if not apparent from the objection); and

(5) Cite authority and include a discussion of the reasons assigned as supporting the motion.

The motion shall be arranged so that the objection, grounds, authority, and supporting reasons follow the verbatim statement of each specific disclosure, interrogatory, deposition question, request for designation of deponent, or request for inspection to which an objection is raised.

(B) Time for Filing. Unless otherwise ordered by the Court, a motion to compel a disclosure or discovery must be filed within the time remaining prior to the close of discovery or, if longer, within fourteen (14) days after service of the disclosure or discovery response upon which the objection is based. The close of discovery is established by the expiration of the original or extended discovery period or by written notice of all counsel, filed with the Court, indicating that discovery was completed earlier.

(C) Procedures. Motions to compel are subject to the general motion requirements set forth in LR 7.1.