The Court believes that parties can and should resolve most discovery disputes. 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, requires communication that takes place face-to-face or by telephone. The Court prefers a face-to-face meeting; the mere exchange of correspondence, including e-mail, normally will not be sufficient to comply with Local Rule 37.2.  The Court considers failure to seriously engage in the meet-and-confer process to be grounds for denial of the motion.

No oversized discovery motions are to be filed. Joint, uncontested, and agreed motions must be so identified in the title and body of the motion. On contested motions, the Court will typically set a date for the responsive brief to be filed. Typically, no reply will be necessary. The Court will then rule on the papers via the CM/ECF system or set a hearing date if one is necessary. All parties must be fully prepared to argue any discovery motion on the date it is noticed for presentment.

The court will not entertain telephone calls from parties trying to resolve issues during a deposition. Parties are directed to make their record and bring any motion practice necessary before the Court following the deposition. The Court notes that Fed. R. Civ. P 30(c)(2) requires that an objection “be noted on the record, but the examination still proceeds; the testimony is taken subject to any objection.” Further, “[a] person may instruct a deponent not to answer only when necessary to preserve a privilege, to enforce a limitation ordered by the court, or to present a motion under Rule 30(d)(3).”

 The Seventh Circuit generally disfavors blanket grants of filing documents under seal. Therefore, when parties wish to file documents under seal, the Court will expect the parties to address whether certain documents should be filed under seal in light of the rulings in, among other cases, Union Oil Co. of California v. Leavell, 220 F.3d 562 (7th Cir. 2000) (strongly rebuking district courts for broadly allowing parties to file documents under seal) and Howe v. Speedway LLC, No. 19‑cv‑1374, 2024 WL 4346631, n.2 (N.D. Ill. Sept. 29, 2024) (citing Baxter Int’l v. Abbott Labs., 297 F.3d 544, 546-47 (7th Cir. 2002); Leavell, 220 F.3d at 567-68)); see also, Old River, LLC v. Autocam-Har, Inc., No. 05-cv-1051, 2005 WL 8179220, at *2 n. 1 (N.D. Ill. Dec. 5, 2005) (“It is not enough to state that material is ‘confidential’ and conclude that it must be kept out of the public record.”). Additionally, the Court requires a courtesy copy of the full briefing containing any materials filed under seal.