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LR 37 DISCOVERY DISPUTES – MOTIONS TO COMPEL a. Declaration Required. No motion relating to discovery may be filed unless counsel for the moving party electronically attaches to the motion a declaration attesting to the following:

1. Counsel, in good faith, has conferred personally with counsel for the opposing party in an attempt to resolve or narrow by agreement the issues raised by the motion;

2. The lawyers have been unable to reach an agreement; and 3. The nature of the disagreement.

An exchange of written communications or a single telephone message will not, by itself, satisfy the requirements of this section.

In the alternative, counsel for the moving party may certify in a written declaration, subscribed under penalty of perjury pursuant to 28 U.S.C. § 1746, that a personal conference with opposing counsel was impossible, and describe the efforts undertaken to schedule the conference. An exchange of written communications or a single telephone message will not, by itself, satisfy the requirements of this section.

No declaration is required under this rule where one party to the discovery dispute is proceeding pro se.

b. Attachments to Motions. A party filing a motion objecting to a discovery request or to the sufficiency of a response to a discovery request must attach to the motion a copy of the disputed request and any response.

c. Deadline for Motions to Compel. Motions to compel must be filed as soon as practicable. In any event, except for good cause shown, motions to compel must be filed within 14 days after the discovery deadline.