Rule 37-1 Pre-Motion Discovery Conferencing Duties of All Counsel.
Rule Text
(a) Good Faith Negotiation Requirement. Prior to filing any motion relating to discovery pursuant to Rules 26 through 37, other than a motion relating to depositions under Rule 30, counsel for the parties and any self-represented 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.
(b) Demanding Party's Specification Letter The party requesting resolution of a discovery dispute shall serve a letter on other counsel identifying each issue and/or discovery request in dispute, stating briefly the moving party's position with respect to each (and providing any legal authority), and specifying the terms of the discovery order to be sought.
(c) Conference Arrangements and Personal Negotiations Requirement
(1) Facilitating a Conference. After service of the letter request, it shall be the responsibility of counsel for the requesting party to make any necessary arrangements for a conference.
(2) Personal Discussions Requirement. To the extent practicable, counsel are encouraged to meet in person at a mutually convenient location. If, in the consideration of time and/or resources, counsel agree that meeting in person is not practicable, the conference may take place telephonically or by video conferencing. Mail or e-mail exchanges are not sufficient.
(3) Completion of Negotiations. Unless otherwise provided by stipulation of the parties, or by written order of the court, the conference shall be completed within 15 days after the moving party serves a letter requesting such conference.