a. Discovery Motions

The Court will not hear or consider any discovery motions unless the parties have complied with the meet and confer requirement under Local Rule 37.2. Any discovery motion must state with specificity when and how the movant complied with Local Rule 37.2.

Parties are reminded that compliance with Local Rule 37.2 requires a good faith effort to resolve discovery disputes and, other than in exceptional circumstances, communication that takes place face to face or by telephone.  The mere exchange of correspondence will not normally be sufficient to comply with Local Rule 37.2.

All parties must be fully prepared to orally argue any discovery motion on the date that it is presented.  The Court may decide discovery motions after oral argument at the motion call and without briefing.  If after argument the Court believes that the motion requires briefing, the Court normally will set an expedited briefing schedule so that the matter can be resolved promptly.

b. Other Motions

The meet and confer requirement can have the same effect on other disputes that it has in connection with discovery disputes.  A candid discussion between the parties prior to filing motions to dismiss, motions for summary judgment, and motions in limine, among others, can limit the scope of such motions or eliminate the need for them to be filed at all.

Thus, the Court will apply the meet and confer requirement not just to discovery motions, but to all motions that a party wishes to file.  The comments above concerning what must be done to comply with the meet and confer requirement will be applied with equal force, and in the same way, with respect to all other motions.