Local Rule Criminal Rule 16.1.a: Meet and Confer Requirement

Criminal Rule 16.1.a Meet and Confer Requirement Not later than fourteen (14) calendar days after the arraignment on an Indictment or Information, the attorney for the defendant(s) and the attorney for the government must confer and attempt to agree on a timetable and procedures for the pretrial disclosure of materials set forth in Fed. R. Crim. P. 16. Generally, this conference should be in person; however, in early disposition (fast track) cases or when it is impractical to meet in person, the conference may be conducted via telephone or email. During the conference, or as soon as practicable thereafter considering the size and complexity of the case, the parties should consider ways in which to ensure the elimination of unjustifiable expense and delay and the expeditious government production of electronically stored information ("ESI") and other voluminous discovery. If discovery includes ESI, the parties must discuss the appropriate form and format of the production of materials containing ESI. To the extent practicable, this material should be produced in a searchable and reasonably usable format. Not later than seven (7) calendar days prior to the first motion hearing, the parties must inform the Court in writing of the agreed upon timetable for the production of discovery, including the Alien Registration File, body-port-or remote cam video, car/vehicle inspection, DEA drug reports, cell phone extraction data, and/or ESI where applicable, as well as the proposed timing for disclosure of expert witnesses under Rule 16, and any areas of disagreement.