Parties are strongly encouraged to resolve and/or narrow discovery disputes prior to filing a discovery motion.

In any motion related to a discovery dispute, the movant shall state when and how the movant complied with Local Rule 37.2, which requires a “live” discussion in person or by telephone (video conference is another acceptable means of communication). Parties shall report the names of the participants, date, length of time, and place/manner of the required discovery conference.  Unless a difficult privilege issue is presented, the Court will ordinarily rule after argument on discovery motions without entertaining briefs.

Parties are reminded that there is no "order" in which discovery must occur, and that one party's failure or inability to respond to discovery requests will not excuse any other party's prompt compliance.

Parties are advised that the Court will not sustain an objection that a particular request is "burdensome" without specific information from knowledgeable sources regarding the amount and nature of the effort required to comply with the request, and the number of documents likely to be generated by compliance.