a.  Discovery Motions

Please see separate link entitled “Discovery Motion Requirements” on Judge McShain’s website.

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.