consider any discovery motion in the absence of a joint stipulation or
a declaration from counsel for the moving party establishing that
opposing counsel (a) failed to confer in a timely manner under L.R.
37-1; (b) failed to provide the opposing party’s portion of the joint
stipulation in a timely manner under L.R. 37-2.2; or (c) refused to sign
and return the joint stipulation after the opposing party’s portion was
added. If such declaration accompanies the motion, then L.Rs. 6-1, 7-
9 and 7-10 apply.
