In addition to complying with applicable provisions of Civil L.R. 7, a motion to compel
further responses to discovery requests must set forth each request in full, followed
immediately by the objections and/or responses thereto. For each such request, the moving
papers must detail the basis for the party’s contention that it is entitled to the requested
discovery and must show how the proportionality and other requirements of Fed. R. Civ. P.
26(b)(2) are satisfied.
